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Association Comments on Short-Term Insurance Proposed Rule

In a Sept. 11 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals commented on proposed changes to short-term, limited-duration insurance.

The proposed rule modifies the definition of STLDI to limit the initial contract period from 12 to three months and limit the maximum coverage period from 36 to four months. The rule also proposes to prohibit the same issuer from issuing multiple STLDI policies to the same policyholder within a 12-month period.

America’s Essential Hospitals supports this modification and urged CMS to provide a clear explanation of coverage in STLDI application notices, particularly regarding limited benefit coverage, lapses in coverage, and the lack of federal financial assistance.

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


About the Author

Julie Kozminski is a senior policy analyst at America's Essential Hospitals.

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