Public Comment Letters

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.

Comment Letter on the Draft 2022 Federal Actuarial Value Calculator Methodology

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.

Comment Letter on the proposed rule, “Securing Updated and Necessary Statutory Evaluations Timely”

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.

Comment Letter on the Proposed Rule, “Affidavit of Support on Behalf of Immigrants”

The Massachusetts Health Connector has voiced strong opposition to the proposed rule on the Affidavit of Support for immigrants, citing concerns over its detrimental effects on both health coverage and economic stability within the state. The letter highlights how the rule could deter immigrant families from accessing essential health care, undermining the Commonwealth’s pursuit of near-universal insurance coverage.

Comment Letter on the proposed rule, “Certain Medical Care Arrangements”

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.

Comment Letter on the Proposed Rule, “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2021; Notice Requirement for Non-Federal Governmental Plans”

The Massachusetts Health Connector provided feedback on the proposed 2021 Benefit and Payment Parameters, emphasizing the importance of maintaining automatic re-enrollment to ensure coverage continuity for residents. The letter highlights the critical need for state flexibility in managing eligibility processes, allowing tailored solutions that align with local market dynamics.