The AHA today submitted comments to the Centers for Medicare & Medicaid Services on the agency's proposed notice of benefit and payment parameters for the 2019 health insurance marketplaces. "While we appreciate CMS's efforts to reduce regulatory burden within the health care system and provide states with increased flexibility, we are concerned that several of the proposals in the rule would reduce patient access to care, including some that could result in health plans that cover fewer benefits and expose patients to greater cost sharing," wrote AHA Executive Vice President Tom Nickels. Specifically, AHA urged CMS to abandon a proposal providing states with more flexibility on setting the essential health benefits package. "Patients would face higher out-of-pocket costs for services no longer covered, which also would not be subject to cost-sharing limits or prohibitions on annual or lifetime limits," AHA said. In addition, AHA expressed concerns with proposals related to network adequacy standards and essential community providers; medical loss ratio; and the navigator program. AHA expressed support for proposals related to special enrollment periods and minimal essential coverage designation for Children's Health Insurance Program buy-in programs. 

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