"[We] first recommend that the final rule includes a broader definition of what constitutes a 'uniform modification.' Second, we urge HHS to permit greater flexibility and defer to employers in determining the content and timing of required notices. Third, we ... urge HHS to allow any individuals with minimum essential coverage to purchase hospital or other indemnity insurance in the individual market. Fourth, we caution against expanding the definition of small group. Fifth, we recommend against imposing an expedited formulary exceptions request at this time. Finally, we urge HHS to focus on ensuring that the electronic enrollment infrastructure is fully operational for all Sm all Business Health Options Programs before incorporating the highly-complex additional functions that an employee choice option would demand."  MORE >>