Affordability, market stability, and consumer protection

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.

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.

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.

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.

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.

The Massachusetts Health Connector and Division of Insurance have shared key feedback on the draft 2022 Federal Actuarial Value Calculator Methodology. The comment letter emphasizes concerns over how the current methodology affects plan design, particularly for bronze-level plans, which are increasingly difficult to keep affordable and within federal standards.

The Massachusetts Health Connector has raised significant concerns about the proposed SUNSET rule, which could lead to the automatic expiration of vital health regulations if not reviewed in a timely manner. The Health Connector warns that this approach risks creating disruptions in health coverage and unpredictability in the insurance market, potentially harming consumers and states that rely on these protections.

The Massachusetts Health Connector has submitted a comment letter addressing concerns about the proposed rule on Certain Medical Care Arrangements. The Health Connector emphasizes the risks of consumer confusion with health care sharing ministries, which often lack the protections of ACA-compliant insurance.