Proposed Rule undermines consumer protections, jeopardizes market stability
Washington (April 19, 2018) – The Alliance of Community Health Plans (ACHP) today calls for maintaining the existing 90-day limit for short-term, limited duration (STLD) insurance plans in its recommendations to the Centers for Medicare and Medicaid Services (CMS). The Proposed Rule undermines comprehensive coverage and care in the individual market by extending short-term plans for up to 364 days and permitting their renewal.
“The Proposed Rule on Short-Term, Limited Duration Insurance is the latest obstacle for American consumers trying to secure comprehensive coverage and care for themselves and their families,” said ACHP President and CEO Ceci Connolly. “Vital components that stabilize our health care market – the individual mandate, cost-sharing reductions, reinsurance – have fallen by the wayside. The proposal to extend short-term plans to 364 days jeopardizes market stability even further and runs the risk of raising premiums.”
Health plans in the individual market include consumer protections that ensure fair treatment, guaranteeing essential health benefits and covering pre-existing conditions. If short-term, limited duration plans were extended to 364 days and made renewable, they would create a parallel, non-compliant market, undercutting comprehensive policies offered to individuals and families. Enrollees in the proposed short-term plans could face higher premiums due to their health status; refusal of coverage based on pre-existing conditions; and lack of coverage for entire categories of benefits, such as maternity care, mental health care or prescription drugs.
“Short-term plans were designed for consumers to use as temporary, stop-gap measures when moving between plans – not as long-term replacements for health insurance,” said Connolly. “A broad, stable risk pool is crucial for providing affordable coverage and care. ACHP believes that other policy options, such as reinsurance, would be far more effective at promoting high-quality, affordable coverage and care for all Americans.”
As community-based, nonprofit organizations, ACHP member plans are committed to providing the highest-quality coverage and care to the more than 20 million individuals they serve across the country. To access the full text of the ACHP comment letter, click here.
The Alliance of Community Health Plans (ACHP) is a national leadership organization bringing together innovative health plans and provider groups that are among America’s best at delivering affordable, high-quality coverage and care. ACHP’s member health plans provide coverage and care for more than 20 million Americans across 32 states and the District of Columbia. These organizations focus on improving the health of the communities they serve and are on the leading edge of innovations in affordability and quality of care, including primary care redesign, payment reform, accountable health care delivery and use of information technology. To learn more, go to www.achp.org and follow ACHP on Twitter @_ACHP.