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NHeLP Comment Letter to CMS on Proposed 2017 Essential Health Benefits Benchmark Plans
National Health Law Program [NHeLP]Link to more items from this source
[Opinion]
Oct. 1, 2015
13 pages. "There is a clear directive in the [ACA] requiring the Secretary of HHS to define the [essential health benefits (EHBs)], and as a legal matter, HHS has no authority to delegate defining the EHBs to states or issuers.... HHS should clarify in written guidance to states that they may supplement when there is insufficient or inadequate coverage of an EHB category.... We urge HHS to eliminate any provision allowing issuer flexibility to substitute benefits."

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