ACAP Comment Letter on 2018 Draft Letter to Issuers

December 1, 2016

Kevin Counihan, Chief Executive Officer
Center for Consumer Information and Insurance Oversight
Centers for Medicare & Medicaid Services
Department of Health & Human Services

Submitted electronically via:

To Director Counihan:

The Association for Community Affiliated Plans (ACAP) thanks you for providing us with an opportunity to comment on the Draft 2018 Letter to Issuers in the Federallyfacilitated Marketplaces. ACAP thanks CCIIO for its efforts to provide clear, practicable guidance for states and Qualified Health Plans (QHPs) for participation in the Marketplace in 2018.

ACAP is an association of 58 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 26 states. Our member plans provide coverage to more than 17 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans for dually-eligible individuals, including nearly half a million Marketplace enrollees. Nationally, ACAP plans serve roughly onethird of all Medicaid managed care enrollees. Seventeen of ACAP’s Safety Net Health Plan members are offering qualified health plans (QHPs) in the Marketplaces for 2017.

Summary of ACAP’s Comments

Please find below a list of ACAP’s comments. ACAP has opted to respond to a select subset of proposals in the draft Letter to Issuers that are particularly relevant to Safety Net Health Plans, rather than all of the guidance. We appreciate CCIIO’s continued willingness to evaluate whether specific programs and provisions are working as intended and update them accordingly. In particular, we appreciate CCIIO’s continued focus on ensuring the Marketplaces work for low-income and vulnerable populations—the population traditionally served by Safety Net Health Plans. ACAP would like emphasize that the comments herein support Safety Net Health Plans in their efforts to serve their communities, which they are generally well-acquainted to by way of their experience with serving Medicaid enrollees.

The positions summarized below are explained in greater detail later in the letter.

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