Response to CCIIO Draft 2015 Letter to Issuers in Federally-Facilitated Marketplaces

The Association for Community Affiliated Plans (ACAP) thanks you for providing us with an opportunity to comment on the Draft 2015 Letter to Issuers in the Federally-facilitated Marketplaces. This draft letter was published February 4, 2014 on the website. ACAP thanks CCIIO for its efforts to provide clear, practicable guidance for states and qualified health plans (QHPs) for participation in the Marketplace in 2015.

We appreciate your willingness to consider our comments.

ACAP is an association of 57 nonprofit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to 10 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans for dually-eligible individuals. Sixteen of ACAP’s member plans opted to participate in the Marketplaces in their states in 2014, and more will follow suit in 2015 and 2016.

The draft Letter covers a wide array of topics, and accordingly we have opted not to respond to all of them, but have restricted our comments to those issues that currently concern us most.

Our positions are explained below.

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