By Joe Touschner

In my last post on HHS’s proposed rules, I mentioned that, like the holidays, the comment deadline would be here before we knew it.  Well here we are in the middle of the holiday season and the December 26 deadline is right around the corner.  It’s likely not something that was on anybody’s list, but CCF has a gift to share for those who would like to provide comments to HHS on these rules—we’re sharing our draft comments that others are free to use as their own, in part or in whole.

CCF Draft Comments on Essential Health Benefits Rule

CCF Draft Comments on Market Reforms Rule

Both rules have a number of provisions that will help children and families access affordable care.  But as you can imagine, we also have a number of suggested improvements.  In the draft comments linked above, we discuss the provisions we support in addition to recommending changes.

Remember that the EHB rule also contains a proposed set of benefits for each state—our comments don’t address those, so be sure to take a look at the proposal for your state at this link.   Once you do, you can comment on the rules at Regulations.gov—EHB here  and market reforms here.

One issue we’re looking at closely is the affordability of dental care for kids, especially those in families who qualify for premium tax credits.  The provisions of the EHB rule on pediatric dental coverage interact with yet another rule HHS proposed recently that deals with the premium tax credits and cost-sharing reductions (CMS-9964-P for those keeping score).  We’re still working out the best recommendations to make given the provisions of both proposals, so please contact us if you’d like to see our final comments on this topic.