The Association for Community Affiliated Plans (ACAP) thanks you for considering our comments regarding the process used by the Center for Consumer Information & Insurance Oversight (CCIIO) to resolve eligibility data inconsistencies related to immigration status and citizenship, and Bulletin 11, “Guidance for QHP Issuers in the Individual Market FFM Regarding Individuals Who Are Determined Not to be Qualified Individuals Due to Data Matching Issues.”
ACAP is an association of 58 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to approximately 11 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans for dually-eligible individuals. Nationally, ACAP plans serve roughly onethird of all Medicaid managed care enrollees. Sixteen of ACAP’s Safety Net Health Plan members have elected to participate in the Marketplaces in 2014.
ACAP supports much of CCIIO’s approach to inconsistencies in 2014. For example, ACAP plans appreciate that terminations will not occur retroactively for individuals whose eligibility is not verified. ACAP also generally supports attempts to avoid gaps in coverage for enrollees.