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AAMC Comments on Notice of Benefit and Payment Parameters for 2014 Proposed Rule

January 4, 2013—The AAMC submitted a Dec. 31 comment letter  to the Centers for Medicare and Medicaid Services (CMS) on a proposed rule related to the Exchanges and insurance marketplace reform under the Affordable Care Act (ACA, P.L. 111-148 and P.L. 111-152): HHS Notice of Benefit and Payment Parameters for 2014 This proposed rule, which was released on Dec. 7, 2012, provides further detail and parameters regarding cost-sharing reductions and the risk adjustment, reinsurance, and risk corridors programs.

AAMC comments focused on the proposed risk adjustment methodology, providing cost-sharing reductions at the point-of-service, and exceptions for student health insurance.  The comments included the following:

  • Supporting risk adjustment to help stabilize premiums by limiting the risk associated with enrolling individuals with unknown health status.  The letter emphasized that the risk adjustment methodology should account for differences underlying health status (generally worse in lower socioeconomic status patients);
  • Strongly supporting CMS’ proposal that a qualified health plan (QHP) issuer must ensure that eligible individuals receive reductions in cost-sharing when the cost-sharing amount is collected at the point-of-service.  AAMC agreed that QHP issuers should be prohibited from creating a system in which eligible enrollees would be required to pay the full cost-sharing requirement and later apply for a reimbursement or refund.  These CMS proposals should be finalized so that cost-sharing reductions help eliminate barriers to accessing necessary health care services; and
  • Explaining AAMC would support CMS’ proposal to treat student health plans as a separate group, which would not be subject to risk adjustment charges and would not receive risk adjustment payments, if exceptions for student health plans proposed in the Health Insurance Market Rules; Rate Review proposed rule are finalized [see Washington Highlights, Dec. 28, 2012].


Ivy Baer, J.D., M.P.H.
Senior Director and Regulatory Counsel
Telephone: 202-828-0499

Allison M. Cohen, J.D., LL.M.
Senior Policy and Regulatory Specialist
Telephone: 202-862-6085

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