January 15, 2019 04:21 pm News Staff – The Academy and five fellow medical professional organizations last week objected to a proposed federal rule that would require health insurance exchange plans that cover certain women's health services to send separate bills.
"We oppose any regulations that make it more difficult for our patients to access critical health services and maintain their insurance coverage," said a Jan. 8 letter(3 page PDF) to HHS Secretary Alex Azar signed by the AAFP, the AMA, the American Academy of Pediatrics, the American College of Obstetricians and Gynecologists, the American College of Physicians, and the American Psychiatric Association.
The proposed Exchange Program Integrity rule would, among other negative effects, jeopardize women's insurance coverage and interfere with the patient-physician relationship, the letter warned.
"The rule imposes additional costs and administrative requirements on health plans that could decrease plans' willingness to cover comprehensive women's health services in the exchanges," the organizations said. "By limiting access to comprehensive women's health coverage in the exchanges, the proposed rule impedes a patient's ability to make the best medical decision for herself and her family" and infringes on the patient-physician relationship.
"We believe this intervention into medical decision-making is inappropriate, ill-advised and dangerous for the health of our patients."
The letter called these impacts "antithetical" to CMS' Patients Over Paperwork initiative, which aims to reduce administrative burden on both health care professionals and health plans.
HHS' and CMS' rule, published in the Nov. 9, 2018, Federal Register, is meant to update implementation of the Patient Protection and Affordable Care Act's requirement that health insurance plans that cover abortion separate premium charges for that coverage from other premium charges. If it goes into effect, insured patients in 24 states and Washington, D.C. -- about 1.3 million persons, HHS estimates -- would receive two bills per cycle, requiring separate payments. The rule says this would support exchange-program integrity by "safeguarding consumers against enrollment in unnecessary or duplicative coverage."
The Academy and its co-signatories disagreed.
"The administration has provided no convincing evidence that health plans are out of compliance with the requirements to segregate premium funds, and this proposal will only burden patients and health plans," the letter said.
The new rule would place "immense administrative burdens" on patients, the letter said, sowing confusion and leaving policyholders exposed to cancellation risks. "Consumers would be required to send two separate payments for one insurance premium: one for the portion covering overarching health services and the other covering select women's health services."
A Kaiser Family Foundation analysis sums up one likely consequence of that burden and confusion: Some policyholders "may think the abortion coverage is a rider and not part of their plan, and decide not to pay the $1 without recognizing that they are making incomplete payments on their full insurance."
The groups' January letter expressed concern about this potential hazard.
"We are fearful that consumers will fall through the cracks by underestimating the consequences of not paying their premiums in full," they wrote. "Indeed, if a consumer fails to pay their monthly premium payment in full -- either intentionally or unintentionally -- the consumer will have 90 days from the date of the missed payment to reconcile their balance or risk termination of benefits."
The letter cautioned that the proposed regulation would "prevent individuals from getting the care they need and especially adversely impact women's health."
"Our organizations oppose efforts to restrict access to basic women's health care in federal and state-based exchanges," the letter concluded. "We urge CMS to remove this provision before issuing a final rule."
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