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AAMC Comments on Medicaid, CHIP, and Health Insurance Marketplace Proposed Rule

February 15, 2013—The AAMC submitted a Feb. 13 comment letter  on a CMS proposed rule to implement provisions of the Affordable Care Act (ACA, P.L. 111-148 and P.L. 111-152) related to Medicaid, the Children’s Health Insurance Program (CHIP), and other health insurance marketplace reforms. The proposed rule, which was published in the Jan. 22 Federal Register, will coordinate eligibility and enrollment processes across insurance affordability programs and streamline applications and appeals.

AAMC’s comments focused on presumptive eligibility determinations by hospitals, proposals to increase nominal cost-sharing limits, and requirements for Medicaid bench-mark and benchmark-equivalent plans (now referred to as “Alternative Benefit Plans”).  In the comment letter, AAMC:

  • Supports expanding authority to make presumptive eligibility determinations to qualified hospitals in all states starting in January 2014;

  • Commends CMS for proposing to require Alternative Benefit Plans to provide essential health benefits (EHB);

  • Strongly opposes any increased cost-sharing for either outpatient or inpatient services for Medicaid patients, because even minimal increases to cost-sharing are likely to have a considerable impact on access to care;

  • Strongly opposes the CMS proposals to increase cost sharing for non-emergency use of the emergency department by allowing cost sharing of up to $8 without a waiver for individuals with family incomes up to 150 percent of the federal poverty line; and

  • Explains how proposed new requirements that hospitals must satisfy before imposing cost-sharing for non-emergency use of the emergency department will be difficult to implement, particularly in medically underserved communities that do not have viable alternatives for timely provision of non-emergency care.


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