Comments on the Proposed Out-Of-Pocket Cost Comparison Tool for the FFM

The Association for Community Affiliated Plans (ACAP) thanks you for providing us with an opportunity to comment on CMS’s “Bulletin on Proposed Out-Of-Pocket (OOP) Cost Comparison Tool for the Federallyfacilitated Marketplaces (FFMs)” released May 29, 2015. ACAP appreciates CCIIO’s efforts to develop userfriendly tools that will aide consumers’ as they shop for coverage on the FFM.

ACAP is an association of 59 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to approximately 15 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 one-third of all Medicaid managed care enrollees. Eighteen of ACAP’s Safety Net Health Plan members have elected to offer qualified health plans (QHPs) in the Marketplaces in 2015.

ACAP recommends that CCIIO test the utility of adding a special tag or label for QHP issuers that also operate Medicaid health plans to the cost comparison tool as well as In 2015, 39 percent of issuers serve both the Medicaid and the Marketplace markets nationwide. We believe adding an indicator to identify these issuers would promote continuity of coverage for individuals “churning” between Medicaid and Marketplace coverage as well as for families with split coverage between the two programs. ACAP understands that there could be unintended negative consequences for issuers that are labeled with an overlap indicator, we therefore are only encouraging CCIIO to study the impacts of adding a tag or label at this time.

ACAP thanks CCIIO for your willingness to discuss this issue with us. If you have any additional questions or comments, please do not hesitate to contact Jenny Babcock (202-204-7518 or

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