The AAMC submitted comments on the Patient Protection and Affordable Care Act (ACA) Notice of Benefit and Payment Parameters for 2023 proposed rule on Jan. 27. The letter outlined the association’s support to strengthen standards for qualified health plans (QHPs) offered through federally facilitated Exchanges and State-based Exchanges on the federal platform.
In its comments, the AAMC noted that it is essential that QHP network standards be structured so that there are sufficient providers and facilities included in a plan’s network to ensure adequate access to a range of care, including specialty care, for consumers. Limiting patients’ access to certain providers can be particularly detrimental for patient groups that already suffer from disproportionate levels of disease and death.
The letter noted the association’s support for the expansion of telehealth services. The waivers put in place by the Centers for Medicare & Medicaid Services during the COVID-19 public health emergency has allowed health care providers to quickly transition to using telehealth services to furnish needed care. This expanded use of telehealth services has enabled providers to maintain continuity of care and reach patients who may have difficulty accessing needed care during the public health emergency. However, the association believes it is premature to provide time and distance credits to QHPs for telehealth services.
Finally, the letter noted the association’s support of expanded collection and extraction of new data elements and stated that the additional data could be used to improve risk adjustment and promote equity in health insurance coverage.