Comments on Affordable Care Act (National Health Reform) Implementation

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Stacey Pogue /(512) 320-0222 x 117
Anne Dunkelberg /(512) 320-0222 x 102

November 1, 2011

CPPP submitted comments on several proposed federal rules that implement pieces of the Affordable Care Act related to Medicaid, Exchanges, premium tax credit eligibility and enrollment, and uniform summaries of insurance benefits. Taken together, these rules outline a sweeping vision for consumer-friendly tools and processes to help people understand and enroll in affordable coverage through Medicaid, CHIP, and the Exchange.

Establishment of Exchanges and Qualified Health Plans

  • Full Comment (pdf)
  • Comments on rules related to the Exchange address steps needed to create consumer-friendly Exchanges. They also provide feedback on the proposed model for partnership Exchanges that would be jointly run by the federal and state governments.

Eligibility for Medicaid and CHIP

  • Full Comment (pdf)
  • Comments on rules related to eligibility for Medicaid and CHIP address policies needed to modernize Medicaid and CHIP eligibility and enrollment systems and ensure a “no wrong door” approach with the Exchange.

Individual-Market Eligibility

  • Full Comment (pdf)
  • Comments on rules related to individual-market eligibility determinations by Exchanges address steps needed to ensure streamlined and accurate eligibility determinations for premium assistance in the Exchange.

Treasury Tax Credits

  • Full Comment (pdf)
  • Comments on rules related to premium tax credits for Exchange coverage stress the importance of ensuring that all members of a family have access to affordable coverage through job-based insurance or the Exchange and safe harbors needed to protect low-income families from inappropriate repayment obligations.

Summaries of Coverage

  • Full Comment (pdf)
  • Comments on uniform summaries of coverage address steps needed to ensure that new, uniform disclosures about health insurance will be as understandable and useful as possible to consumers shopping for and enrolled in insurance. Stacey Pogue, senior policy analyst, joined other consumer representatives to the National Association of Insurance Commissioners in submitting these comments.