On behalf of America’s Health Insurance Plans (AHIP), thank you for the opportunity to offer comments in response to the U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services (CMS) Notice of Benefit and Payment Parameters (NBPP) for 2019 Proposed Rule (CMS-9930-P), published in the Federal Register on November 2, 2017.
Many regulatory changes proposed in the NBPP would promote State flexibility, support
innovation, and promote affordability. We support policies that promote the role of States to regulate their own insurance markets, and to have greater input into the products being offered to their residents. It is critical that policies to promote State flexibility are workable, result in minimum disruptions to consumers, and do not increase costs or administrative burdens for States or issuers. Such policies should encourage innovative plan designs that balance comprehensive, evidence-based benefits with affordable coverage. A stable regulatory environment with clear rules of the road is critical to ensure that such changes are successful and provide needed predictability for States and issuers.