ACR submits comments to CMS regarding 2019 benefit and payment parameters proposed rule
ATLANTA – In its response yesterday to the 2019 Benefit and Payment Parameters proposed rule, which governs the state and federal health exchanges created by the Affordable Care Act, the American College of Rheumatology (ACR) urged the Centers for Medicare and Medicaid Services (CMS) to reconsider proposals that would reduce health exchange insurance coverage, affordability and patient choice.
"The ACR is committed to ensuring that Americans living with rheumatic diseases have access to high-value, high-quality healthcare," said Dr. David Daikh, MD, PhD, President of the ACR. "While we are pleased to see CMS is considering changes that would reduce drug costs and promote pricing transparency, we are deeply concerned about proposed changes that would make it more difficult for our patients to access and afford the care they need."
Rheumatology leaders urged CMS to reconsider several proposals that would reduce insurance coverage, affordability and patient choice under the state health exchanges, including:
- Essential Health Benefits: The ACR opposes CMS' proposal to allow states to select their own essential health benefit (EHB) benchmark plans, warning that this could create a "race to the bottom" wherein states will seek the least acceptable coverage at the lowest cost, thereby restricting patient access to care. This flexibility could also lead states to severely restrict biologic drug coverage. The ACR urged CMS to ensure that clinical decisions about treatments – particularly those relating to drug therapies – remain in the hands of providers. States and insurers should not be allowed to determine treatment plans, nor should they be able to mandate the use of a certain therapy over another.
- Plan Rate Review: The ACR is deeply concerned about CMS' current proposal to increase the rate review threshold from 10 to 15 percent. Under this proposal, plans that have annual premium increases that are less than 15 percent would not be subject to the review process for "unreasonable" premium increases, or the review would be less stringent. Raising this threshold would create additional financial barriers for patients seeking affordable insurance coverage. Since premium increases compound annually, the proposal could also make it harder for patients to afford plan copayments and deductibles.
- Minimum Essential Coverage for CHIP Buy-in Programs: The proposed rule aims to categorically designate CHIP buy-in programs that provide identical coverage to state Title XXI CHIP programs as "minimum essential coverage" without first undergoing an application process. Doing so provides no guarantee that coverage under these programs would be the same, leaving children who suffer from rheumatic conditions in a dangerous medical limbo. The ACR urges CMS to withdraw this proposal, or at minimum provide a reasoned analysis for the new standard and codify it into existing regulations.
"Adequate and affordable health insurance coverage is absolutely critical to managing chronic and complex rheumatic diseases and conditions," said Daikh. "We urge CMS to reconsider proposals that would severely reduce insurance coverage, access and patient choice under the state and federal health exchanges. The ACR will continue to serve as a resource to CMS as it works to expand patient access to affordable care."
To read the comment letter, click here.