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AAMC Comments on Short-Term, Limited-Duration Insurance Proposed Rule

April 27, 2018—The AAMC submitted April 23 a comment letter to the Centers for Medicare and Medicaid Services (CMS) in opposition to the agency’s proposal to amend the maximum length of short-term, limited-duration (STLD) insurance policies from three months to 12 months. Additionally, the AAMC commented on the agency’s proposed notice provided to STLD enrollees and applicants.

STLD plans, which are not required to comply with the Affordable Care Act (ACA P.L. 111-148 and P.L. 111-152), were designed to fill temporary coverage gaps. According to the AAMC letter, expanding access to these plans will create serious issues concerning segmentation of the insurance market, as well as increased patient exposure to inadequate health coverage. The AAMC recommends that in order to protect consumers, CMS should, at a minimum, require that STLD minimum benefits packages cover the essential health benefits required by the ACA, and, rather than expand STLD plans, work to improve the current health insurance marketplace options for consumers.

The AAMC comments underscore that CMS should ensure that the consumer protections that currently exist be maintained and emphasize that the proposed notice is inadequate to alert consumers of STLD plans’ significant shortcomings in coverage and out-of-pocket cost. The proposed notice, which merely refers patients to review their own policies, stands to undercut CMS’s transparency efforts relating to coverage and cost, according to the AAMC.


Mary Mullaney
Director, Hospital Payment Policies
Telephone: 202-909-2084

Andrew Amari
Hospital Policy and Regulatory Specialist
Telephone: 202-828-0554


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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
Senior Legislative Analyst, Govt. Relations
Telephone: 202-903-0806