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Association Letter Responds to Market Stabilization Proposed Rule

In a March 7 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals expressed concerns about proposed changes that could harm the integrity of qualified health plan (QHP) networks.

In February, CMS proposed new standards to strengthen and stabilize the individual and small group markets under the Affordable Care Act’s (ACA’s) health insurance marketplaces for 2018. Overall, the proposed rule provides more flexibility to states and insurers. Of particular interest to members of America’s Essential Hospitals were included proposals to change standards related to network adequacy reviews, essential community provider (ECP) inclusion, and ECP lists.

In its comments, America’s Essential Hospitals recommended that:

  • network adequacy reviews should ensure patients have access to all hospital services within their plan’s network;
  • CMS amend the ECP standard to require that QHP issuers offer contracts, in good faith, to every willing ECP hospital in each county of a plan’s service area; and
  • CMS allow issuers to identify, through a write-in process, all ECPs in their provider networks.

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


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