NHeLP's Comments to Basic Health Program Proposed Rule

Executive Summary

NHeLP commends CMS for its efforts to implement the Basic Health Program (BHP). BHP has the potential to greatly benefit low-income consumers and help ensure the success of the Affordable Care Act (ACA). Enabled by meaningful administrative rules, the Basic Health Program could reduce premiums and out-of-pocket costs for financially-strapped households, improve enrollment rates, reduce barriers to needed care, and support continuity of care. NHeLP's comments support many of the provisions in CMS's proposed BHP regulations, and offer suggestions for changes that would help this program meet its potential. Specifically, our recommendations are aimed at ensuring consumer protection and input, promoting adequate and stable financing states need to be able to take up this option, facilitating continuity of care, and encouraging delivery system innovations that improve care quality.
November 25, 2013
 
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-2380-P
Baltimore, MD 21244-8016

RE: CMS-2380-P – Comments on September 25, 2013 Notice of Proposed Rulemaking: Basic Health Program: State Administration of Basic Health Programs; Eligibility and Enrollment in Standard Health Plans; Essential Health Benefits in Standard Health Plans; Performance Standards for Basic Health Programs; Premium and Cost Sharing for Basic Health Programs; Federal Funding Process; Trust Fund and Financial Integrity 
 
 
Dear Sir/Madam:

The National Health Law Program (NHeLP) is a public interest law firm working to advance access to quality health care and protect the legal rights of low-income and underserved people. We appreciate the opportunity to provide comments in response to the proposed regulations related to the Basic Health Program, published in the Federal Register on September 25, 2013.

We commend CMS for its efforts to implement the Basic Health Program (BHP). BHP has the potential to greatly benefit low-income consumers and help ensure the success of the Affordable Care Act (ACA). Enabled by meaningful administrative rules, the Basic Health Program could reduce premiums and out-of-pocket costs for financially-strapped households, improve enrollment rates, reduce barriers to needed care, and support continuity of care. In short, the Basic Health Program has the potential to help the Affordable Care Act meet its key goals of making affordable coverage available to everyone and maintaining stable, continuing care for those enrolled.
 
We appreciate the chance to offer comments on these proposed regulations. We support many of the provisions in the proposed regulations, and offer suggestions for changes that would help this program meet its potential. Specifically, our recommendations are aimed at ensuring consumer protection and input, promoting adequate and stable financing states need to be able to take up this option, facilitating continuity of care, and encouraging delivery system innovations that improve care quality. 
 
We submit the following comments. Please note, our comments are listed in order of the sections in the proposed rules; the order of the issues raised in our comments does not reflect their priority.

 
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