Sections of the 28-page letter include: Guaranteed Availability / Guaranteed Renewability -- Additional Strategies Are Necessary to Encourage Participation, Minimize Disruption, and Mitigate Rate Shock; Adjusted Community Rating -- Additional Steps Can Be Taken to Promote Affordability of Coverage and Minimize Disruption of Rates in the Current Market; The Single Risk Pool Requirements Provide Flexibility For Developing Rates and Innovative Health Care and Payment Models; Consistent Treatment of Student Health Plans is Critical to Promote Affordability and Minimize Disruption; and The Regulatory Review Process Should Continue to Be Streamlined to Reduce Duplication, Promote Efficiency and Minimize Administrative Costs.

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