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AHIP Comment Letter to Agencies: Over-the-Counter Preventive Items and Services Available Without a Prescription (PDF)

15 pages. "[AHIP supports] the Tri-Departments' interest in increasing access to OTC preventive health care options, starting with OTC contraception, with appropriate guardrails. [AHIP's comments] emphasize the need for health insurance providers to promote access and affordability by directing them to preferred retail settings ... [and] provide recommendations on ensuring implementation places minimal burdens on consumers, providers, pharmacists, and health insurance providers."

AHIP Comment Letter to HHS on Proposed Regs for Nondiscrimination in Health Programs and Activities (PDF)

31 pages. "[AHIP offers] detailed comments on how HHS should maintain regulatory flexibility to focus on quick and streamlined access to interpretation, with written translations provided upon request.... [AHIP's] comments include additional recommendations to modify notice timing and frequency, as well as other suggestions to further improve the notice requirements ... AHIP recommends HHS convene a stakeholder process to gather additional input about the use and application of clinical algorithms."

Estimates of the Potential Reduction in Health Care Costs from AHIP's Affordability Proposals (PDF)

11 pages. Excerpt: AHIP's affordability proposals1 could yield substantial savings for the U.S. health care system, provided that a large-scale and coordinated set of public and private initiatives is launched in the coming years. Taken together, AHIP's proposals have the potential to trim national health expenditures (NHE) by as much as 9 percent by the year 2025, compared with current baseline trends.

AHIP Letter to OCR on Cyber Breach Notification Obligations Following Change Healthcare Incident (PDF)

"At [the May 1 hearing] held by the House Energy & Commerce Committee, United CEO Andrew Witty said, 'we are offering to take full responsibility for all notification obligations for everyone involved in this.' [AHIP supports] this approach and agree that guidance from the Office of Civil Rights should clearly state that only Change has an obligation to perform breach notification in this context. That clarity would avoid tens of millions of Americans being left confused, frustrated and inundated by multiple notifications."

AHIP Letter to HHS Requesting Extension of Enforcement Discretion Under the No Surprises Act (PDF)

"AHIP is requesting  ... that the Departments and OPM extend the exercise of enforcement discretion under the NSA beyond May 1, 2024, with the possibility of future extensions pending the release of further guidance, final resolution of still pending legal challenges or as may otherwise be appropriate. [This letter outlines] detailed explanations of many of the challenges health plans currently face as they seek to align their processes with the result of the TMA III decision."

AHIP Comment Letter to CMS on Advance Notice of Methodological Changes for Calendar Year (CY) 2025 for Medicare Advantage Capitation Rates and Part C and Part D Payment Policies (PDF)

54 pages. "AHIP has significant concerns that certain elements of the MA and Part D Advance Notice could diminish the value and affordability of the MA benefits that millions of seniors and people with disabilities count on ... As proposed, many of these changes included in the Advance Notice would lead to significant variability in the MA program across geographic markets ... In addition, plans are continuing the multi-year implementation of changes required under the Inflation Reduction Act (IRA), underscoring the impact of dynamic and uncertain market conditions facing beneficiaries and their coverage."

AHIP Comment Letter to CMS on Proposed Regs for Federal Independent Dispute Resolution Operations (PDF)

25 pages. "AHIP appreciates the Departments' interest in resolving communication issues throughout the IDR process and addressing the ongoing challenges for parties to determine accurate contact and plan information necessary to initiate and ultimately resolve a dispute. While well-intentioned to address these information-sharing challenges, the proposed IDR registry would likely not achieve its intended objectives."

Summary of AHIP's Key Comments on the Proposed MHPAEA Regs (PDF)

"[T]he proposed regulations ... miss an opportunity to improve on MHPAEA's progress ... Instead, the proposed regulations go far beyond current law and impose new, unworkable, and illogical standards on a process that was already in dire need of greater clarity."

AHIP Comment Letter to Tri-Agencies on Proposed MHPAEA Requirements (PDF)

41 pages. "The proposed regulations have significant legal, policy, and operational flaws and should not be finalized. Perhaps more importantly, the proposed rules will not achieve the goals of increasing access to mental health care or substance use disorder treatment.... [T]he proposed rules exceed any reasonable interpretation of the text or purpose of both MHPAEA and the CAA."

AHIP-Led Coalition Aims to Reduce Coverage Losses Amid Pending Medicaid Redeterminations

"AHIP and several other healthcare organizations launched the Connecting to Coverage Coalition ... in an effort to make the upcoming Medicaid redetermination process run smoothly. The coalition's website includes studies on Medicaid redeterminations and frequently asked questions for enrollees. AHIP also released a report that shows 53.6% of those who will lose coverage will transition to employer-sponsored insurance and 21.2% will become uninsured."