AHIP’s comments strongly emphasize the need to assure an affordable EHB benefit package that promotes access to high-quality and cost-effective care for patients and consumers. The major recommendations from the letter to HHS include:
- Support state flexibility (as a two-year transitional approach) and assure that state benchmark plans are affordable. We support state flexibility as a two-year transitional approach and strongly recommend that HHS encourage states to use this flexibility to create the most affordable package. AHIP also recommends that HHS examine the potential cost of the benchmark approach — with a focus on affordability for small businesses and families — and assure that the EHB package promotes value and high-quality care.
- Advance the goals of an evidence-based and more effective health care system by establishing a process for a rigorous, evidence-based review of any new proposed mandates — as well as existing mandates — based on their efficacy, clinical effectiveness, and cost. As part of this analysis, HHS should examine the cost and medical evidence of mandates and develop a framework for excluding some state mandates from inclusion in the EHB package.
- Support benefit design flexibility to assure that patients have access to safe, clinically effective, and affordable health care services. As recognized in the Bulletin, allowing plans flexibility to design benefits within the 10 statutory EHB categories “would provide greater choice to consumers, promoting plan innovation through coverage and design options, while ensuring that plans providing EHB offer a certain level of benefits.”
- HHS should issue timely guidance to states on the process for selecting the benchmark plan, and issue guidance on related standards on cost-sharing and actuarial value as soon as practicable. We also recommend that HHS establish a deadline—no later than June 30, 2012 — for states to select an EHB benchmark. If states do not select the benchmark plan by the deadline, HHS should specify the fallback plan as the largest small-group plan in the state by the deadline.