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AAMC Comments on Health Insurance Market Rules; Rate Review

December 28, 2012—The AAMC submitted a Dec. 26 comment letter to the Centers for Medicare and Medicaid Services (CMS) on a proposed rule for Health Insurance Market Rules; Rate Review related to health insurance exchanges (Exchanges). The AAMC’s comments focused on student health insurance, catastrophic coverage plans, and the rate review process.

The comment letter includes strong support for CMS’s proposal to provide exceptions for student health plans from the ACA’s guaranteed availability and renewability requirements. Given the differences between the student health insurance market and other forms of individual coverage, as well as the continuing need to provide students with health insurance, the AAMC believes the final rule should allow issuers to maintain a separate risk pool for student health insurance coverage.

The comment letter also notes concern that offering catastrophic plans could potentially lead to underinsurance in those populations that elect to enroll only in catastrophic coverage plans. The AAMC recommends that CMS should monitor limits and the size of deductibles to ensure that neither beneficiaries nor providers are being adversely affected by these plans. If that is not the case, the agency also should be willing to propose changes.

The AAMC believes the need for CMS to emphasize to states that broad solicitation of public comments is an important factor in effective rate review. States that conduct their own rate reviews reporting requirements should have to provide evidence of a robust mechanism to receive and respond to public comments. The AAMC letter recommends that states in which CMS conducts a rate review should be encouraged to establish their own mechanisms for receiving and responding to public comments to allow them to move towards increasingly transparent and effective rate review.

The proposed rule was released Nov. 26 and is a step in implementing exchanges, mandated by the Affordable Care Act (ACA, P.L. 111-148 and P.L. 111-152) to begin in 2014. 


Jane Eilbacher
Policy and Regulatory Specialist
Telephone: 202-828-0896


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806