Take Action! Use these handy talking points to comment to HHS on Essential Health Benefits (Due 1/31)
(Brought to you by your friends at the HIV Health Care Access Working Group (HHCAWG), who developed these handy-dandy talking points to help you submit comments on the HHS Essential Health Benefits package comments.)
EHB BULLETIN: WHAT IT MEANS
On December 16, 2011, the Department of Health and Human Services (HHS) released an “Essential Health Benefits Bulletin.” The Essential Health Benefits package (EHB) will define what health plans must cover in the exchanges and the expanded Medicaid program as health reform is implemented. This bulletin did not provide detailed information on what benefits must be included in the EHB package, but rather indicated that HHS will allow each state flexibility to create its own benchmark for what the EHB should be.
Specifically, the bulletin indicated that HHS would allow each state to choose a benchmark plan to use as a model for its EHB from one of four basic options: (1) the largest plan by enrollment among the three largest small insurance products in the state’s small group market; (2) any of the largest three state employee health benefit plans by enrollment; (3) any of the three largest national Federal Employee Health Benefits Program (FEHBP) plan options by enrollment; or (4) the largest commercial insurance non-Medicaid Health Maintenance Organization (HMO) operating in the State. In the event that a state does not make its own selection of a benchmark plan, then HHS proposes the default plan to be the largest plan by enrollment in the state’s small group market.
HHS also indicated that insurers, too, could have flexibility to make substitutions among the ten benefit categories defined by law as well as within individual benefits, meaning that even within a state individual plans could be very different in terms of benefits included.
For more information, please visit the archives of HIVHealthReform.org. EHB posts.
This approach fails to create a high national standard for benefits coverage and will result in significant variability in coverage from state to state. A bare bones health benefits package jeopardizes access to the services that people with HIV and AIDS and others with complex medical conditions need to stay healthy and productive. The approach means that what’s covered under one of the 10 required benefit categories will vary by state and limits on particular services, including the number of drugs covered within certain drug classes, will vary by state. Allowing state flexibility to choose benchmark plans that may not cover essential HIV and AIDS services does not meet the letter and spirit of the Affordable Care Act’s (ACA’s) anti-discrimination mandates, nor does it forward the goals of the ACA to expand access to meaningful health care coverage and to provide a robust national standard of coverage.
WHAT YOU CAN DO
Comments to HHS on this EHB bulletin are due January 31, 2012. It is critical that HHS hear from you about why more specific guidance on the EHB is important, including safeguards and protections, to ensure meaningful access to health care for people living with HIV and AIDS and other individuals with complex medical conditions. To make your voice heard, you can email your comments to EssentialHealthBenefits@cms.hhs.gov.
If you need suggestions on what to include, HHCAWG has developed Talking Points to help guide your response. You can also look at the comments submitted by HHCAWG for suggestions, or to use as a template.
Download this alert (Word)
Download the talking points (PDF or Word)
Read the full HIV EHB comments (PDF)
Read the federal fact sheet
Read the HHS Essential Health Benefits Bulletin
Federal white paper on benefits in small group and state and federal plans
Federal fact sheet on individual market benefits
Category: HIVHealthReform.org Blog