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AHIP Comments on HHS Notice of Benefit and Payment Parameters for the 2020 Proposed Rule

Comment Letter

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On behalf of America’s Health Insurance Plans (AHIP), thank you for the opportunity to offer comments in response to the Department of Health and Human Services (HHS) Proposed Notice of Benefit and Payment Parameters for 2020 (“Payment Notice”), published in the Federal Register on January 24, 2019 (CMS-9926-P).

AHIP is the national association whose members provide coverage for health care and related services to millions of Americans every day. Through these offerings, we improve and protect the health and financial security of consumers, families, businesses, communities and the nation. Americans deserve access to comprehensive, quality, affordable coverage. AHIP is committed to advancing policy solutions in support of this goal.

We appreciate the Department’s continued efforts to promote stability in regulatory requirements and lower administrative burdens related to implementing the Affordable Care Act (ACA). HHS specifically proposes solutions to lower costs for consumers, ensure accuracy of core ACA programs including risk adjustment and premium tax credits, and promote transparency. We share these goals and our recommendations aim to balance these objectives with ensuring Americans have access to affordable, comprehensive coverage. However, we are concerned some of the changes proposed by the Department would undermine stability of the individual market, decrease enrollment, and make coverage less affordable for Americans. Read our comment letter here.