Comments on HHS Notice of Benefit and Payment Parameters for 2018: Proposed Rule

October 6, 2016

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

Submitted via Re: CMS-9937-P

Dear Director Counihan:

The Association for Community Affiliated Plans (ACAP) respectfully submits comments regarding HHS Notice of Benefit and Payment Parameters for 2018: Proposed Rule.

ACAP is an association of 57 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 offer qualified health plans (QHPs) in the Marketplaces in 2016.

Summary of ACAP’s Comments

ACAP has chosen to respond to a subset of proposals in the draft Notice that are particularly relevant to Safety Net Health Plans, rather than to the entire rule. ACAP is supportive of numerous provisions throughout the rule and appreciates 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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