The AAMC submitted comments Thursday (PDF) to the Centers for Medicare & Medicaid Services on the Notice of Benefit and Payment Parameters proposed rule for 2027, relating to issuers offering qualified health plans (QHPs) through federally facilitated Marketplace and state-based Exchanges on the federal platform. Exchanges are entities, established under the Patient Protection and Affordable Care Act (P.L. 111-148, PDF), through which qualified individuals and qualified employers can purchase health insurance coverage in QHPs.
The AAMC’s comments focused on the effect the CMS’ proposals would have on access and affordability and urged the agency not to finalize policies that raise costs for beneficiaries, restrict network adequacy, or hinder access to care. The AAMC asked the agency to maintain their current policy regarding network adequacy time and distance criteria and their standard for demonstrating a sufficient number and geographic distribution of Essential Community Providers to ensure reasonable access to care and allow consumers to exercise their right to choose their health insurance and provider. Further, the AAMC urged the CMS not to move forward with allowing the use of non-network plans or expanding access to non-comprehensive, high-cost catastrophic plans as a means to address patient affordability.