Common Sense Standards Would Help Exchanges Be Consumer Friendly – Say Ahhh! A Children’s Health Policy Blog

The Affordable Insurance Exchanges, as envisioned by the
Affordable Care Act, have great potential to help children and families secure
quality health coverage that is competitively priced and supported by federal
tax credits for those who qualify. 
As Say Ahhh! readers know, states will operate exchanges under
guidelines set by the federal government. 
The Department of Health and Human Services released its initial
proposal for these guidelines in July and asked for comment from the
public.  As you might imagine, we
here at Georgetown CCF had a number of comments to make when we got a look at
the proposed regulations.  While
the proposed guidelines are a good start, we have some concerns that they don’t
go far enough to ensure that the potential of the exchange marketplace becomes
a reality for children and families. 

Georgetown CCF has drafted a set of comments to HHS
Secretary Kathleen Sebelius asking that several essential steps be taken to
strengthen the regulation to ensure that children, youth, and their parents
receive the care they need when families purchase insurance through the
exchanges.  We strongly support the
ACA’s vision and the proposed rule’s call for a single, streamlined application
accessed through “no wrong door” to ensure all children and families will be
determined eligible for the coverage option that matches their
circumstances.  In other areas, our
comments ask the Secretary to strengthen the regulation in the following key

* Exchange governance structures should be free of
conflicts of interest and exchange boards should be comprised of a majority of
true consumer representatives.

* All consumer assistance tools, including notices,
should be designed and coordinated to meet the needs of a diverse range of
consumers, including families with mixed immigration status, children with
special health care needs and those with limited English proficiency and
cultural or physical barriers to coverage.

* Open enrollment, special enrollment and disenrollment
procedures should minimize gaps in coverage and avoid disruptions in access to
a usual source of care.

* Families should have access to the right health care
providers.  To ensure network
adequacy, exchanges should develop standards that are subject to HHS approval;
such standards should require that Qualified Health Plans (QHPs) have a robust
panel of pediatric providers; and exchanges should be required to monitor
adequacy of QHP networks.

We know we’re not the only regulation-readers out there
who are eager to comment on this first set of exchange standards.  And the more HHS hears from those who
are looking out for consumers, the better.  So please feel free to use our comments as a template for
your own or don’t hesitate to contact if you’d like to talk through any of the
issues we raise.  You can reach me
at [email protected].  Comments
on these proposed regulations are due to HHS by September 28.

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