Essential Health Benefits Coalition Submits Comments to HHS Responding to December EHB Guidance Bulletin

WASHINGTON, Jan. 31, 2012 /PRNewswire-USNewswire/ -- The Essential Health Benefits Coalition, a broad-based organization composed of groups representing large and small employers from various sectors of the U.S. economy, pharmacy benefit managers, and health plans operating in every state, submitted comments to the Department of Health and Human Services (HHS) yesterday detailing specific concerns with the essential health benefits bulletin issued by HHS in December and its ability to promote the affordability of health coverage for small employers and individuals.

"As HHS finalizes the essential health benefits package regulation, we want to emphasize our concerns regarding the affordability of coverage for small employers and individuals under the Affordable Care Act.  We are pleased HHS is giving states flexibility to structure their own EHB packages using private market coverage options in use today to serve as benchmarks.  Yet these benchmark options are subject to the same state mandates that today keep coverage unaffordable and out of reach for many small employers and individuals," said Neil Trautwein, chairman of the Essential Health Benefits Coalition and vice president and employee benefits policy counsel for the National Retail Federation.

The coalition offered a number of recommendations to address the affordability of a final essential health benefits (EHB) regulation, including:

  • The EHB package should evaluate benefits, including state benefit mandates, from both a cost and medical effectiveness perspective. The process for updating the EHB package should also be done from a cost and medical effectiveness perspective.  These are both recommendations made previously by the Institute of Medicine (IOM) that the coalition strongly supports.
  • The EHB package should not limit cost-sharing tools available to employers that enable them to offer, and workers to access, affordable health coverage. 
  • Only current benefits in effect as of March 1, 2012, should be allowed to be considered for the benchmark EHB package – new state benefit mandates should not be allowed to be added retroactively.
  • Just as the December bulletin provided states significant flexibility to design and choose plans, so too should employers be provided flexibility to design and choose health coverage in a competitive marketplace that is most affordable for them and their employees.

The coalition's complete comments submitted to HHS are available on the EHBC website.

"We urge HHS to consider an approach that balances reasonably comprehensive benefits with affordability for employers and individuals.  A final rule that does otherwise will make health coverage more expensive for employers and individuals to purchase, and make jobs more difficult for employers to create," the coalition wrote in its comments.

The Affordable Care Act (ACA) requires that everyone in the United States have health insurance beginning in 2014.  Health plans for individuals and small businesses must include essential health benefits (EHB), which fall under 10 general categories: ambulatory patient services; emergency services; hospitalization; maternity and newborn care; mental health and substance use disorder services including behavioral health treatment; prescription drugs; rehabilitative and habilitative services and devices; laboratory services; preventive and wellness services and chronic disease management; and pediatric services including oral and vision care.  The Institute of Medicine in October provided HHS its recommended criteria for determining and regularly updating the EHB package.  HHS issued a bulletin in December providing guidance to the states for determining an EHB package.  The Secretary of Health and Human Services is expected to issue a final regulation for an EHB package this year.

The growing membership of the Essential Health Benefits Coalition includes the National Retail Federation, U.S. Chamber of Commerce, National Federation of Independent Business, National Association of Manufacturers, National Association of Wholesaler-Distributors, National Association of Health Underwriters, Blue Cross and Blue Shield Association, Retail Industry Leaders Association, Prime Therapeutics, America's Health Insurance Plans, ExpressScripts, Pharmaceutical Care Management Association, American Osteopathic Association, National Association of Dental Plans, Delta Dental Plans and the Council for Affordable Health Insurance.



SOURCE Essential Health Benefits Coalition