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(Augusta) The largest
consumer health advocacy group in Maine, Consumers for Affordable
Health Care (CAHC), submitted its public comments on the regulations
proposed by the U.S. DHHS regarding the creation of state health
insurance exchanges (Exchange). The Affordable Care Act creates state
exchanges - which become operational on January 1, 2014 - to serve as
"marketplaces" where consumers can purchase health insurance
from an array of affordable options. There will be subsidies in the
Exchange for those who qualify. CAHC was joined in its submission by
Maine Center for Economic Policy, Maine Equal Justice Partners, Maine
Parent Federation, Maine People's Alliance, Maine Women's Lobby, and
the Maine Women's Health Campaign.
"It is important to
weigh in on the proposed federal regulations since they will impact how
each state implements their own Exchange. The Exchanges exist to
benefit consumers and we hope to see strong regulations guaranteeing
that is the case throughout design and implementation of each state's Exchange"
said CAHC Policy Director Mitchell Stein. "If a state does not
fully comply with the final regulations when implementing their own
Exchange, the federal government can step in and take over the
program."
Many of the comments
focused on the transparency of the exchange, ensuring that consumers
are represented in the governance of exchange, that there is no
conflict of interest among those making decisions about the exchange
the rate review process, and setting minimum requirements for state qualified
health plans (QHPs) to
meet.
Among the recommendations
submitted by CAHC are:
- Strengthening
the proposed rules on who governs the Exchange We
believe that any entity that has a potential financial conflict of
interest, including hospitals, physicians, insurers, and brokers
should not be given a governing role in the Exchange;
- The addition of
a consumer advocate to the list of Stakeholders the Exchange must
consult with;
- All insureds
within a market area fund the ongoing operations of the Exchange;
- Improving the
standards of the Navigator role so that there is no financial
conflict of interest and to ensure that the Navigator is well
versed in both public and private insurance options;
- Requiring an
Exchange to fulfill its promise of allowing individuals and small
businesses to receive similar benefits and pricing as large
businesses by exercising the leverage that large purchasers
exercise through selectively contracting;
- That the Exchange
consider network adequacy and geography standards when certifying
that a QHP's network is acceptable;
- A statement that
we agree with a number of other priorities submitted by Consumers
Union.
CAHC also suggested that
consumer assistance is a critical aspect of the Exchange. CAHC
recommends that each state maintain a consumer assistance program (CAP)
and that the same source of funding for the Exchange fund the CAP. CAHC
included three "Lessons from the Implementation of Massachusetts
Health Reform" (published by the Blue Cross Blue Shield Foundation
of MA in March 2011) in its submission. Those lessons are:
- Develop
and support a broad array of community-based outreach, enrollment
and retention activities that help uninsured residents sign up for
and maintain health coverage;
- Connecting
uninsured residents to coverage and care requires intense
statewide effort that draws upon the knowledge and experience of
local service groups and organizations; and
- Health reform
implementation is an ongoing process that requires continuous
improvement based on feedback from consumers, employers, providers
and other stakeholders.
The deadline for submission
was October 31 at 5:30 pm.
The complete copy of public
comments submitted by CAHC can be found here.
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