The Asian & Pacific Islander American Health Forum (APIAHF) appreciates the opportunity to provide comments on the February 17th proposed rule, Patient Protection and Affordable Care Act; Market Stabilization, docket number CMS-9929-P. We are writing to express our deep concerns about multiple provisions in the proposed rule that would reduce access to healthcare for consumers, several of which may have a disproportionate impact on minority and immigrant populations. In addition, the proposals, if adopted, would lead to instability in the marketplace.
We oppose formalizing restrictions on consumers applying for special enrollment periods (SEPs), such as requiring documentation, preventing changing metal tiers or requiring proof of continuous coverage, that will suppress health coverage levels. Our comments focus on the disparate negative impact that shortening open enrollment would have and urge the Centers for Medicare & Medicaid (CMS) to maintain its current length. We also oppose proposals to allow greater de minimis variation in actuarial value, increasing consumer cost sharing and reducing the value of premium tax credits. We additionally oppose requiring consumers to back-pay missed premium payments before enrolling in coverage, a proposal that violates the ACA’s promise of guaranteed renewability of coverage. Finally, we ask CMS to maintain network adequacy standards, and not void federal protections in favor of potentially weaker state rules or reducing requirements for plans to include essential community providers.
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