This post is to alert you that Georgetown CCF has drafted
a letter in response to the Bulletin issued by HHS in December. We raise a number of concerns with the
Bulletin’s approach to essential health benefits and ask that HHS made a number of changes to better protect
benefits for children and their families.
The letter asks HHS to:
* Ensure children’s needs are taken into account–The
benchmark plans identified in the bulletin are predominately employer-based
plans. We think states should have
an option to choose a benefit package that has been designed with children’s
developmental needs in mind, like Medicaid’s EPSDT benefit.
* Define pediatric services as including but not limited
to oral and vision care–While the Bulletin discusses only oral and vision care
for kids, we believe there are other services, like speech therapy or more
frequent durable medical equipment, that Congress intended children to receive
under this category of services it included as a requirement for the EHBs.
* Define medical necessity–Since a determination of
medical necessity will affect whether a child can access the essential health
benefits, we believe it is crucial for the Secretary to set a standard
definition of this concept that insurance plans must follow.
* Limit insurer flexibility–The Bulletin suggests that
insurers would have the authority to alter the essential health benefits. We believe this will take away a key
feature of exchange–apples-to-apples comparisons between plans.
* Assure a transparent process of benchmark selection and
updating–Ensuring meaningful opportunities for public participation will be key
to protecting the interests of children, families, and all insurance
We plan to submit the letter by the date for responses
provided in the Bulletin: Tuesday,
January 31. We encourage other
organizations to provide comments, as well, and if you would like to use our
letter for inspiration or outright copying, please do so! Remember, too, that since HHS explained
its approach in a Bulletin rather than a formal proposed rule, it can still
consider comments that come in after the January 31 date. But don’t wait too long as there will be no shortage of health reform guidance and rulemaking filling all of our
inboxes in the months ahead.