By Joe Touschner
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 areas:
* 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 jdt38@georgetown.edu. Comments on these proposed regulations are due to HHS by September 28.
