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AHIP Comments To HHS In Response To Proposed Notice Of Benefit And Payment Parameters For 2021

posted by AHIP

on March 3, 2020

Today, AHIP submitted comments in response to the Department of Health and Human Services (HHS) Proposed Notice of Benefit and Payment Parameters for 2021. Americans deserve a stable market that provides them with access to affordable coverage choices. We appreciate the Department’s work to promote stability and lower administrative burdens, and many of the proposed regulatory changes included in the Payment Notice meet this goal.

However, we are deeply concerned the Department is considering modifications to automatic reenrollment that would create an arbitrary and undue burden on the lowest income enrollees to maintain subsidies that make coverage affordable.

Below are a few additional takeaways from our comment letter:

  • We support finalizing the clarification that health insurance providers may determine whether to apply accumulator programs to drug manufacturer coupons, or other drug manufacturer direct assistance to address high drug prices.
  • We recommend adopting changes for the 2021 risk adjustment model, including recalibrating the model based on enrollee-level EDGE data, continuing to apply cost-sharing reduction adjustments, and maintaining the same parameters for the high-cost risk pooling program.
  • We support efforts that continue to advance access to health plans that leverage the principles of value-based insurance design (V-BID).

Our full comments can be found by clicking below

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