The AAMC submitted comments on Jan. 27 in response to the Centers for Medicare & Medicaid Services’ (CMS’) request for information (RFI) on potential changes to the conditions health plans must meet to satisfy the essential health benefits (EHBs) requirements. The association stated its support of certain changes to EHBs that focus on consumers’ access to health insurance products that provide meaningful coverage at an affordable price.
The letter noted that to safeguard consumers’ access to insurance coverage that meets their needs, any changes to the EHBs must be clearly communicated to consumers by requiring health plans and states to use plain language to inform consumers of the changes. The letters asked the CMS to eliminate plans that are not subject to the EHB requirements and offer less comprehensive insurance.
Utilization management tools are frequently used by insurers to control utilization of certain services. However, these tools can cause delays in patients’ ability to receive timely, medically necessary care. The letter also asked that plans be required to post to their websites which services require utilization management tools. Further, any midyear changes that require utilization management should be limited to ensure beneficiaries continue to have access to needed medical care. Moreover, these tools, particularly prior authorization, can add to physician burden and burnout. The letter asked the CMS to align prior authorization procedures in the Marketplace with those proposed in Medicare Advantage.
The letter called on the agency to expand the use of telehealth to ensure access to needed care, including behavioral health services. The association also noted that the CMS should require plans to include audio-only telecommunications to furnish services to some patients. Lastly, the letter stated that reimbursement rates for telehealth services, including behavioral health services, should be the same as in-person visits.