Below is this week’s update on the Affordable Care Act. As always, thank you for all you do every day for cancer patients and their families.
ACS CAN Comments on Interim Final Rule on Lifetime and Annual Limits
ACS CAN submitted comments to the Department of Health and Human Services (HHS) on the Interim Final Rule that was released by HHS in June. The rule would implement provisions of the Affordable Care Act relating to preexisting condition exclusions for children, lifetime and annual dollar limits on benefits, rescissions and patient protections. Overall, the rule is strong and expands patients’ access to health care. ACS CAN’s comments focus on several specific concerns relating to the structure of the rules on lifetime and annual limits.
ACS CAN recommends that the Interim Final Rules be revised to include an anti–abuse provision to prevent plans from simply placing new limits on plan benefits as an alternative to the now prohibited limits on annual dollar coverage. The Interim Final Rule allows insurers and employers to apply non-monetary limits to specific benefits, such as incidences of treatment or the number of days of care. For patients with chronic illnesses that require a higher annual level of health care utilization, the burden of annual non-monetary limits could be as damaging as annual monetary limits in creating barriers to coverage.
ACS CAN also recommends that the reinstatement rule for individual policies be revised to create greater parity between the group and individual markets. Under the Interim Final Rule, a participant in a group health plan is eligible for re-enrollment if he or she has reached the plan’s lifetime limit prior to the effective date of the Interim Rules. However, this reinstatement opportunity does not apply to individuals who reached their lifetime limits on individual health insurance coverage. This is a major concern because we believe most consumers who reach a lifetime limit on their health plan are in the individual market.
Christopher W. Hansen
President
American Cancer Society Cancer Action Network (ACS CAN)