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Association Comments on Draft 2019 Letter to Issuers in the Federally Facilitated Marketplace

America’s Essential Hospitals urged the Center for Consumer Information and Insurance Oversight to ensure that qualified health plan (QHP) networks include essential hospitals that serve low-income and medically underserved populations.

This recommendation came in a Dec. 11 letter commenting on the Draft 2019 Letter to Issuers in the Federally Facilitated Marketplaces. The Letter to Issuers includes provisions to increase state flexibility that mirror those outlined in the 2019 Payment Notice Proposed Rule, to which America’s Essential Hospitals also recently submitted comments.

In the letter, America’s Essential Hospitals recommended:

  • using network adequacy reviews to ensure that patients have access to all hospital services within their plan network;
  • amending the essential community provider (ECP) standard to require QHP issuers to offer contracts, in good faith, to every willing ECP hospital in each county of a plan’s service area; and
  • strengthening mechanisms to inform providers about the ECP petition process and allowing issuers to identify all ECPs in their provider networks.

The Department of Health and Human Services updates the list of ECPs annually. Providers have until Dec. 22 to fill out the ECP Petition for the 2019 plan year to be added to the list.

Contact Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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