Many of the Centers for Medicare & Medicaid Services’ proposals to help stabilize the Health Insurance Marketplaces could make participation more appealing to insurers and consumers, but several “threaten consumer access to coverage and care, particularly for vulnerable populations who rely on essential community providers,” AHA told the agency in comments submitted yesterday. For example, allowing silver plans with an actuarial value as low as 66% would decrease the overall tax credit available to consumers, noted AHA Executive Vice President Tom Nickels. “This would have wide-ranging implications for the 85% of marketplace consumers who rely on the tax credits to purchase coverage.” AHA also strongly disagrees with the agency’s proposal to reduce the percentage of essential community providers a plan must contract with, which could result in networks that cannot meet the needs of vulnerable populations in their service areas. “We encourage the agency not to finalize a uniform reduction in the ECP contracting and instead continue to allow for integrated delivery systems to meet an alternate ECP standard,” Nickels said. In addition, the association urged CMS to provide an exceptions process as part of any pre-enrollment verification program for Special Enrollment Periods.