January 31, 2012
Letter
To: HHS Secretary Kathleen Sebelius
From: Neil Trautwein, National Retail Federation
Re: Request for Information on the Essential Health Benefits Bulletin
The Essential Health Benefits Coalition (“EHBC”) appreciates the opportunity to provide comments in response to the “Essential Health Benefits Bulletin” as issued by Department of Health and Human Services’ (HHS’s) Center for Consumer Information and Insurance Oversight (CCIIO) on December 16, 2011.
As you finalize the definition of the Essential Health Benefits (EHB) package, we want to emphasize our concerns regarding the affordability of coverage for small employers and individuals under the Affordable Care Act (ACA). HHS seeks to give states flexibility to structure their own EHB package using private market coverage options in use today to serve as benchmarks. Yet these benchmark options are subject to the same state mandates that today keep coverage unaffordable and out of reach for many small employers and individuals. We urge HHS to consider an approach that balances reasonably comprehensive benefits with affordability for employers and individuals. A definition that does otherwise will make health coverage more expensive for employers and individuals to purchase and make jobs more difficult for employers to create.
Excerpt from recommendations:
Specifically, we urge the Department to reiterate that the Bulletin reflects the statutory requirements that:
* The EHB package does not dictate cost sharing requirements.
* Use of benefit limits included within benchmark plans is not barred.
* Future state mandates will not be added to the benchmark plan.
* Use the benchmark plan only to define the 10 categories of EHBs required by the ACA, and not any additional benefits that the benchmark may cover.
Members of the Essential Health Benefits Coalition Steering Committee:
American Osteopathic Association
America’s Health Insurance Plans
Blue Cross Blue Shield Association
Express Scripts Inc.
National Association of Health Underwriters
National Association of Manufacturers
National Association of Wholesaler-Distributors
National Federation of Independent Business
National Retail Federation
Pharmaceutical Care Management Association
Prime Therapeutics
Retail Industry Leaders Association
U.S. Chamber of Commerce
http://ehbcoalition.org/wp-content/uploads/2012/02/EHBC-Comments.pdf
Comment:
By Don McCanne, MD
HHS has proposed that “essential health benefits” for plans under the Affordable Care Act need meet only the minimal standard of state regulated plans in the small group market. Now a coalition of the usual suspects which push self-serving reforms is proposing to further weaken the “essential health benefits” standard.
The details of their recommendations are not nearly as important as the fact that this maneuver represents what has been wrong with the reform process all along. The vested interests have been in the front seat while the guileless patients have had to accept their work product – a mandate to purchase unaffordable under-insurance, amongst many other flawed policies.
Instead of fighting over the definition of minimal essential benefits in a highly flawed health financing program, we should be joining with the nation’s patients in demanding that our elected leaders quit listening to these self-serving interests and instead enact a program that puts patients in the front seat – an improved Medicare for all.
Addendum: Members of the American Osteopathic Association (AOA) may want to advise their leadership that, as a patient-oriented organization, AOA should immediately withdraw from this dastardly coalition.