AAMC Comments on CMS Marketplace Integrity and Affordability Proposed Rule

The AAMC submitted comments (PDF) on April 9 in response to the Centers for Medicare & Medicaid's (CMS) Marketplace Integrity and Affordability proposed rule [refer to Washington Highlights, March 21]. The CMS' proposals aim to revise standards for issuers offering qualified health plans (QHPs) through federally facilitated Exchanges and state-based Exchanges on the federal platform as established by the Patient Protection and Affordable Care Act (P.L. 111-148, PDF).

The association's comments highlighted the potential negative downstream effects from proposals that limit access to the Marketplace and urged CMS to explore options to maintain the integrity of the Marketplace without jeopardizing enrollee coverage and access. Specifically, the AAMC asked CMS not to impose additional barriers to coverage, but rather incentivize healthy individuals to select and maintain coverage to prevent adverse selection. Comments also urged the agency to ensure that enrollees are notified of any changes in updated plan cost information or financial assistance for the upcoming plan year prior to closing the open enrollment period. Additionally, the AAMC urged CMS not to finalize its proposal to alter its interpretation of "lawfully present" for the purposes of determining eligibility in a QHP or insurance affordability programs to exclude those with Deferred Action for Childhood Arrivals status.