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ACR Responds to Association Health Plans Proposed Rule

In comments submitted today to the US Department of Labor in response to its Association Health Plans (AHP) proposed rule, the American College of Rheumatology urged Administration officials to protect essential health benefits and other consumer protections that make it possible for individuals living with rheumatic diseases to access comprehensive and affordable healthcare.

Under the proposed rule, trade associations would have leeway to offer health insurance that would be exempt from many of the coverage requirements for small-group plans under the Affordable Care Act. In its comments to the U.S. Department of Labor, the ACR cautioned that loosening these requirements could lead to weak and insufficient coverage for Americans living with rheumatic diseases, thereby jeopardizing their access to needed healthcare.

“The ACR is concerned that loosening these consumer protections will reduce our patients’ access to care, either through weaker coverage or by driving up their premiums,” said Dr. David Daikh, PhD, MD, President of the ACR. “Our patients require continuous access to specialized care to manage pain and avoid long-term disability. Therefore, it is imperative that the Administration ensure that Americans living with rheumatic diseases be afforded adequate protections under these new rules.”

Specifically, the ACR urged the Administration to:

  • Prevent AHPs from selecting their own essential health benefits, which could create a “race to the bottom” among insurers who may seek the lowest permitted coverage levels;
  • Protect patients from discriminatory insurer practices such as discouraging enrollment of sicker employees, caps on coverage and services, increased co-insurance for patients, and tiering of high-cost specialty medications. The Administration should develop, issue and continually update guidance regarding discriminatory practices;
  • Ensure that AHP networks include adequate coverage for specialized services such as physical therapy and pediatric rheumatology – particularly for patients living in rural and underserved areas where access to such services is already limited. The Administration should also clarify that for AHPs whose networks cross state boundaries, plans are held to the laws that offer the most protections for patients; and
  • Put in place requirements to ensure patients are well-informed of their rights and responsibilities with respect to AHP coverage and that a timely, transparent, and fair process is in place for appealing coverage decisions.

“The ACR is dedicated to ensuring patients with arthritis and rheumatic diseases have access to continuous, comprehensive, and high-quality care,” Dr. Daikh continued. “We appreciate the opportunity to offer our input and are ready to work with the Administration and lawmakers to ensure policies are implemented in a manner that protects patient access to critical rheumatologic care and treatments.”


The author has no conflicts of interest to disclose related to this subject

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