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Consumers Union Comment Letter to HHS on Proposed Standards for Essential Health Benefits, Actuarial Value, and Accreditation (PDF)
Consumers Union 
[Opinion] Dec. 23, 2012
"[Consumers Union] strongly support[s] the following provisions of the proposed rule: [1] Selection of a single actuarial value (AV) calculator to ensure uniformity when measuring health plan coverage levels; [2] A robust standard for measuring employer minimum value; and [3] A strong process for identifying state EHB-benchmark plan designs. However, to realize the full promise of health reform, [CU urges] revision of some of the proposed regulations, particularly those dealing with the AV calculator, benefit substitution for essential health benefits (EHB), and anti-discrimination provisions."
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