December 26 is the deadline for submitting comments on the proposed rule for Essential Health Benefits released recently by the Department of Health and Human Services (HHS). Essential Health Benefits are the core package of items and services that must be offered in individual and small group health plans under the Affordable Care Act.
This is an incredibly important topic, but one that might slip by unnoticed because:
- The proposed rule is long and complex
- The time to review it is short and during a holiday period
- The benefits differ from state to state and
- Some people may assume, mistakenly, that this will never affect them because the rule initially only applies to individual and small group plans.
However, it’s important to remember that the Essential Health Benefits being identified now will serve as the minimum floor of coverage for the state marketplaces that were created by the Affordable Care Act. As such, they will create a precedent on which future comparisons will be made, possibly for years to come.
Essential Health Benefits are being defined in many different ways. For instance, is medical food for management of a chronic disease like PKU an Essential Health Benefit? In some states, it will be covered while in others, it may not. The same may be true for many other health services.
NORD will be reviewing the documentation and submitting comments by the deadline. In the meantime, we encourage our constituents to read this proposed rule and an accompanying one on health insurance market reforms (see links in blog posted Nov. 28 by Diane Dorman).
What would you consider Essential Health Benefits for the rare disease of particular concern to you? If you were going to go out and buy health insurance, which benefits would you prioritize most?
Your comments, posted below, will be helpful as we consider NORD’s response to the proposed rule.