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Association Comments on Third-Party Premium Assistance Rule

America’s Essential Hospitals submitted comments May 13 on the Centers for Medicare & Medicaid Services’ (CMS’) interim final rule regarding third-party premium assistance for health insurance marketplace enrollees. The interim final rule requires qualified health plans (QHPs) to accept third-party premium assistance on behalf of enrollees from Ryan White HIV/AIDS Programs; Indian tribes, tribal organizations, or urban Indian organizations; and state or federal government programs.

In its comments, the association urged CMS to allow providers as well to offer premium assistance and cost-sharing to individuals obtaining coverage through the marketplaces (exchanges). The association noted that provider-based assistance would help strengthen the marketplaces and ensure vulnerable populations have access to needed care.

America’s Essential Hospitals also asked CMS to clarify that QHPs are required to accept premium and cost-sharing assistance from private, nonprofit foundations. In Feb. 7 guidance, CMS stated private, nonprofit foundations may make premium and cost-sharing payments on behalf of QHP enrollees who meet criteria based on financial status and not health status. However, that language was omitted from the interim final rule. Additionally, the association asked CMS to clarify the requirement for QHPs to accept premium payments from state and federal government programs also extends to local government programs.

Please contact Xiaoyi Huang, JD, director of policy, at or 202.585.0127 with questions.


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