Public Comment Letters - Massachusetts Health Connector

Comment Letter on the proposed rule, “Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2027; and Basic Health Program”

The Massachusetts Health Connector and the Division of Insurance provided detailed feedback on the proposed 2027 HHS health insurance rules, noting support for the Centers for Medicare & Medicaid Services' goals to improve affordability, strengthen program integrity, and help people maintain access to coverage. The agencies also raised concerns that several proposals could limit state flexibility, create timelines that are difficult to carry out, and weaken the insurance risk pool.

Comment Letter on the proposed rule, “Inadmissibility on Public Charge Grounds”

The Massachusetts Health Connector has strongly opposed the Department of Homeland Security's proposed rule on "Inadmissibility on Public Charge Grounds." In a detailed comment letter, the Health Connector argues that the rule would create widespread fear and uncertainty, discouraging immigrant families, including those with U.S. citizen children, from enrolling in the health coverage they are legally entitled to receive.

Comment Letter on the proposed rule, “Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability”

The Massachusetts Health Connector submitted a public comment letter addressing concerns about the proposed Centers for Medicare & Medicaid Services (CMS) rule, "Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability." The letter highlights potential negative impacts on Massachusetts's unique merged individual and small group insurance market, including increased premiums, harm to the risk pool, and administrative burdens. The letter also emphasizes the Commonwealth's success in achieving near-universal coverage and maintaining program integrity through tailored, data-driven approaches.

Comment Letter on the proposed rule, “HHS Notice of Benefit and Payment Parameters for 2026”

The Massachusetts Health Connector provided detailed feedback on the 2026 NBPP proposed rule, advocating for key measures that enhance transparency in Marketplace operations and codify the use of silver-loading practices to maintain affordability. The agency also supports incorporating Pre-Exposure Prophylaxis (PrEP) into risk adjustment models to promote equitable access to preventive care. Highlighting the burden of medical debt, especially on vulnerable communities, the Health Connector emphasizes the need for increased education on financial assistance programs.

Comment Letter on the proposed rule, “HHS Notice of Benefit and Payment Parameters for 2025”

The Massachusetts Health Connector provided detailed feedback on the 2025 NBPP proposed rule, voicing strong support for robust network adequacy standards, a permanent special enrollment period (SEP) for low-income individuals, and expanding access to routine adult dental benefits. These measures aim to strengthen consumer protection, reduce barriers to coverage, and enhance access to essential health services.

Comment Letter on the proposed rule, “Requirements Related to the Mental Health Parity and Addiction Equity Act”

The Massachusetts Health Connector has voiced strong support for the proposed rule “Requirements Related to the Mental Health Parity and Addiction Equity Act,” emphasizing the critical need for equal access to mental health and substance use disorder benefits. The proposal comes at a time when the mental health crisis has intensified nationwide and in Massachusetts, with rising rates of psychological distress, substance use disorders, and barriers to care.

Comment Letter on the proposed rule, “Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Accident and Health Insurance”

The Massachusetts Health Connector submitted a comment letter in support of proposed changes to regulations surrounding Short-Term, Limited-Duration Insurance (STLDI) and related coverage options. These updates aim to protect consumers and promote equitable access to comprehensive health care.

Comment Letter on the Proposed Rule, “Clarifying Eligibility for a Qualified Health Plan Through an Exchange, Advance Payments of the Premium Tax Credit, Cost-Sharing Reductions, a Basic Health Program, and for Some Medicaid and Children’s Health Insurance Programs”

The Massachusetts Health Connector has voiced its strong support for the proposed rule to expand health coverage eligibility to Deferred Action for Childhood Arrivals (DACA) recipients. By including DACA recipients as "lawfully present," this rule would grant access to crucial health programs such as Marketplace subsidies, Medicaid, and the Basic Health Program.

Comment Letter on the proposed rule, “Coverage of Certain Preventive Services under the Affordable Care Act”

The Massachusetts Health Connector submitted a comment letter expressing strong support for the proposed rule, "Coverage of Certain Preventive Services under the Affordable Care Act." This rule aims to expand access to preventive services, including contraception, while addressing exemptions for entities with religious or moral objections.

Comment Letter on the Proposed Rule, “HHS Notice of Benefit and Payment Parameters for 2024”

The Massachusetts Health Connector has submitted its feedback on the proposed 2024 Notice of Benefit and Payment Parameters (NBPP) rule, supporting key measures like allowing income attestation flexibility, advancing auto-enrollment policies, and broadening special enrollment period options. These actions aim to enhance coverage access while reducing administrative hurdles that often deter individuals from securing insurance.