In comments submitted to the Centers for Medicare & Medicaid Services (CMS) today, the National Partnership for Women & Families condemns the proposed marketplace stability rule, stating it would make enrollment harder and care more expensive for women and families and would undermine critical network adequacy protections in the Affordable Care Act (ACA).

“With this proposed rule, CMS claims it is trying to improve the stability of the health insurance marketplace and increase affordability for consumers, but this rule would do the opposite. It would increase costs and make it more difficult for people to enroll in health coverage and it would compromise people’s ability to access their preferred providers,” said National Partnership President Debra L. Ness. “We strongly urge the administration to find ways to promote real market stability without undermining the coverage gains and protections made under the ACA and through the marketplace.”

In its comments, the National Partnership expresses concern that elements of the proposed policy will negatively affect access, coverage and choice of provider by:

• Shifting costs to consumers;
• Cutting the annual open enrollment period in half, giving people less time and support to find and enroll in the plan that’s right for them; and
• Weakening network adequacy standards thereby decreasing access to preferred health care providers, including essential community providers.

The National Partnership’s comment letter strongly urges CMS not to gut federal network adequacy protections or lower the participation standard for health plans with regard to Essential Community Providers (ECPs). The comments emphasize the critical role that ECPs play in delivering care to low-income people and the negative effects that blocking access to ECPs would have on many women’s ability to access high-quality, affordable health care.

The National Partnership’s comments can be found here.