By Joe Touschner

We have been offering our insights on essential health benefits through a series of blog posts.

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 consumers. 

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.