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AHIP Submits Comments on 2024 Payment Notice Proposed Rule

Comment Letter

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Published on Feb 1, 2023

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On January 30, 2023, AHIP submitted comments in response to the Department of Health and Human Services (HHS) Notice of Benefit and Payment Parameters for 2024 (“Payment Notice”).

The ACA Marketplaces are stable and growing, experiencing record-breaking enrollment year-after-year. For 2023, more than 16.3 million Americans selected a Marketplace plan – including a 21% increase of Americans who purchased from the Marketplace for the first time.

Furthermore, Marketplace consumers had a choice of between 6 and 7 Qualified Health Plan (QHP) issuers on average for 2023, providing robust competition that offered hardworking American families more choices, better quality, and lower costs.

AHIP’s comment letter focuses on recommendations that promote affordability, competition, and consumer choice while minimizing disruption for Americans. Specifically, AHIP’s comments address:

  • Non-Standardized Plan Option Limits: AHIP strongly opposes HHS’ proposal to limit the number of non-standardized plan options to two plans per product network type and metal level and instead recommends HHS adopt a refined meaningful difference standard.
  • Network Adequacy: AHIP recommends HHS improve the network adequacy review process, provide additional flexibility to preserve access in exceptional circumstances, and delay appointment wait time standards until plan year 2025.
  • Standardized Plans: AHIP requests that HHS defer to issuers when establishing prescription drug tiers that effectively balance cost, access, and quality.
  • Essential Community Providers: AHIP asks HHS to maintain the current ECP standards and not apply thresholds to specific categories and delay the addition of Rural Emergency Hospitals to the Other ECP Providers category until plan year 2025.
  • Annual Eligibility Redetermination: AHIP encourages HHS to improve consumer decision support tools and education and opposes HHS’ proposal to modify the reenrollment hierarchy to override consumer choice.
  • Special Enrollment Periods: AHIP supports HHS’ proposals to promote access and mitigate coverage gaps, particularly during the upcoming period of Medicaid redeterminations. These include the proposed changes to the coverage effective date rule and proposal to allow Exchanges the option to implement a special rule for consumers who lose Medicaid/CHIP coverage. However, AHIP generally cautioned HHS from implementing SEPs that could have significant adverse consequences for the individual market.

Please see AHIP’s comments for further detail.