Public Comment Letters

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.

Comment Letter on the Proposed Rule, “Nondiscrimination in Health Programs and Activities”

The Massachusetts Health Connector has expressed strong support for the proposed rule to reinforce nondiscrimination protections in health programs and activities. Advocating for the inclusion of protections based on sexual orientation, gender identity, and language proficiency, the Health Connector emphasizes the critical role these measures play in ensuring equitable access to health care for all.

Comment Letter on the Proposed Rule, “Affordability of Employer Coverage for Family Members of Employees”

The Massachusetts Health Connector has submitted a comment letter in support of the proposed rule addressing the affordability of employer-sponsored family coverage. The letter strongly endorses including family coverage costs in affordability assessments, aligning with the ACA's goals of ensuring meaningful access to affordable health care.

Comment Letter on the Proposed Rule, “HHS Notice of Benefit and Payment Parameters for 2023”

The Massachusetts Health Connector submitted feedback on the proposed 2023 NBPP rule, raising concerns about the State Exchange Improper Payment Measurement program due to its potential burden on state flexibility and innovation. The letter advocates for maintaining flexibility in actuarial value variations to preserve affordable plan options for consumers.

Comment Letter on the Proposed Rule, “Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond”

The Massachusetts Health Connector has provided robust feedback on the proposed 2022 NBPP updates, strongly supporting the repeal of the direct enrollment option to safeguard consumer protections and ensure transparency in health plan selection. The letter also endorses the restoration of the 2015 Section 1332 waiver guidance to uphold comprehensive coverage standards and promote health equity.