Documents

PPC Documents, Letters and Statements

• Patient Organizations Applaud Release of Affordable Care Act Rule to Protect All Patients from Discrimination When Accessing Health Care

  04/26/2024

  Our organizations, which represent hundreds of millions of patients and consumers facing serious, acute, and chronic health conditions across the country, thank the Department of Health and Human Services for taking this significant step to protect all patients from discrimination with the new Section 1557 final rule.  This new rule reinstates protections for everyone regardless of race, color, national origin, sex, age, or disability in covered health programs and activities, consistent with statutory intent and case law. 

• PPC Comments RE: Florida CHIP Eligibility Extension

  04/24/2024

  Comments supporting Florida’s proposal to expand CHIP coverage to 300% of the FPL, but also urging CMS to closely review the premium requirements and policies in order to protect children from gaps in care and ensure the premiums will not disrupt access to coverage or violate the the Consolidated Appropriations Act of 2023.

• PPC Comments RE: Maryland HealthChoice 1115 Reentry Demonstration

  04/19/2024

  Comments applauding the state’s work to improve health equity in this waiver, supporting the proposal to provide pre-release services for the justice-involved population, and urging CMS to approve this request. Comments also encourage the state to expand eligibility to all individuals who qualify for Medicaid coverage 90 days prior to release, regardless of their medical history, and to eliminate cost-sharing requirements for this population for at least 12 months during their reentry period.

• PPC Response to to Employee Retirement Income Security Act (ERISA) 50th Anniversary Request for Information

  04/05/2024

  Letter suggesting that the Committee’s Request for Information (RFI) provides an opportunity to consider ways in which employer-sponsored insurance (ESI) can be strengthened to ensure families struggling with high out-of-pocket costs aren’t shouldering the burden of unchecked healthcare costs. At a minimum, the letter indicates that the Committee should prioritize additional resources for the Department of Labor (DOL) to oversee and enforce existing requirements for employer-sponsored plans, including protections against discriminatory benefits, fraud, and insolvencies, and the recently enacted provisions of the Consolidated Appropriations Act (CAA).

• 35 Patient Organizations Celebrate Rule to Protect Patients from Short-Term Health Plans

  04/02/2024

  On behalf of patients with serious and chronic health concerns, our 35 groups welcome and celebrate the Biden Administration’s new rule that will better protect patients from short-term, limited-duration health plans, a risky form of low-quality health coverage.

• PPC Comments RE: Arkansas 1115 Demonstration Project

  03/27/2024

  Comments supporting the proposed coverage for incarcerated individuals who are otherwise eligible for Medicaid for up to 90 days prior to release, identifying issues with beginning the coverage pre-release, and and raising concerns about the post-release policies the state has proposed.

• PPC Comments re Pennsylvania Keystones of Health 1115 Demonstration

  03/13/2024

  PPC comments applauding the state’s work to improve health equity in this waiver and support the inclusion of continuous eligibility for children and pre-release coverage and continuous eligibility for justice-involved populations. Our organizations urge CMS to approve these requests and offer the following comments on Pennsylvania’s Keystones of Health Demonstration:

• PPC Comments RE: NV 1332 Waiver Federal 

  03/13/2024

  PPC comments indicating support for ensuring that Nevada’s healthcare programs provide quality and affordable healthcare coverage. To that end, we support implementation of a new coverage program to improve access to affordable coverage, as required by Senate Bill 420.
  
  Nevada’s waiver application seeks pass-through funding primarily to support an individual market reinsurance program. Though we agree that reinsurance can play a role in addressing affordability, the benefits of such a program flow primarily to individuals at higher incomes who are not eligible for federal premium tax credits. It does not make coverage cheaper for people — generally at lower incomes — who already qualify for federal subsidies.
  
  For this reason, many of our organizations urged the state to use pass-through dollars to fund a premium subsidy program for low-income Nevadans during the state comment period. In the absence of an accompanying premium subsidy program, we believe it is particularly important that the new Battle Born State Plans (BBSP), as well as the non-reinsurance elements of the state’s waiver proposal, are implemented in ways that will safeguard access to care for low-income residents and that are likely to produce demonstrable reductions in health disparities.

• PPC Comments RE: Minnesota PMAP+ Continuous Eligibility Amendment

  03/06/2024

  PPC comments supporting the inclusion of multi-year continuous eligibility for young children and 12-month continuous eligibility for 19- and 20-year-olds, and urging CMS to approve this request. PPC organizations are committed to ensuring that Minnesota’s Medicaid program provides quality and affordable healthcare coverage. 

• PPC Comments Re: Hawaii 1115 Demonstration Extension

  03/06/2024

  PPC comments supporting the inclusion of continuous eligibility for children and pre-release coverage for justice-involved populations, and urging CMS to approve these requests. PPC organizations are committed to ensuring that Hawaii’s Medicaid program provides quality and affordable healthcare coverage, and this demonstration is consistent with Hawaii’s efforts to support healthy families and improve equitable access to care. 

• Letter to HHS Requesting Finalization of Proposed Rules Vital to the Patient Community

  02/23/2024

  Letter expressing appreciation of the Administration’s leadership in developing and proposing rules that protect and expand Americans’ access to quality, affordable health care and requesting finalization, no later than April 2024, of the Section 1557; Nondiscrimination in Health Programs and Activities Proposed Rule, the Mental Health Parity; Requirements Related to the Mental Health Parity and Addiction Equity Act (MHPAEA), the Short-Term, Limited-Duration Insurance Proposed Rule, and several more related to the Medicaid, CHIP, and the Basic Health Program.

• Comments Re: Florida Children’s Health Insurance Program Eligibility Extension

  02/21/2024

  Comments supporting Florida’s proposal to expand CHIP coverage to 300% of the FPL, and urging the state to remove premium requirements to comply with the Consolidated Appropriations Act guidance, ensuring that children do not have gaps in coverage.

• Comments Re: Proposed Rescission of Association Health Plan Final Rule

  02/20/2024

  Comments explaining that it is appropriate and necessary for the Department to rescind this rule and offering additional comments in strong support of its proposal to do so.

• PPC Comments RE: Kentucky TEAMKY 1115 Demonstration Amendment

  02/09/2024

  Comments applauding the state’s work to improve health equity in this waiver, supporting the inclusion of pre-release coverage for justice-involved populations, and urging CMS to approve the request.

• PPC Comments on Medicaid Unwinding Interim Final Rule

  02/02/2024

  Overall, PPC supports this rule and commends CMS efforts to provide technical assistance as the agency monitors and conducts oversight over the impact of the unwinding on healthcare coverage for low-income children, families, and adults. PPC also believes a few areas in the rule that could be strengthened as discussed in the comments. 

• PPC Statement on Medicaid Unwinding and Protecting Patients’ Access to Medicaid Coverage in 2024

  01/26/2024

  PPC organizations strongly urge governors and states to take additional action to protect coverage for the children and families over the next year and offer suggestions for policies which do just that.

• PPC Comments RE: Notice of Benefit and Payment Parameters for 2025

  01/08/2024

  Comments expressing appreciation for the administration’s ongoing commitment to improving the accessibility, affordability, and adequacy of care for all patients and confidence that many of the policies included in the proposed rule will continue to advance these shared goals.

• Comments RE: the Federal Independent Dispute Resolution Operations under the No Surprises Act

  01/02/2024

  Comments on a proposed rule applauding the Departments’ efforts to improve the Independent Dispute Resolution process outlined under the No Surprises Act.

• Comments RE: Nevada Section 1332 Waiver Application

  12/20/2023

  Comments supporting the Nevada’s commitment, as codified by Senate Bill 420, to implement a new coverage program for improving access to affordable coverage, and urging the state to use pass-through funds generated by the waiver to support a premium subsidy program for Nevadans with low-incomes.

• Comments RE: North Carolina Medicaid Reform Demonstration Extension Request

  12/20/2023

  Comments applauding the North Carolina’s work to improve health equity under this waiver and supporting the inclusion of continuous eligibility for children and pre-release coverage for justice-involved populations.

• PPC Statement RE: Strengthening Consumer Protections in Association Health Plans

  12/19/2023

  Patient groups applaud the Department of Labor’s newly proposed rule strengthening consumer protections in association health plans (AHPs).

• Comments RE: Proposed Rule on Comments on Processes for Assessing Compliance with Mental Health Parity and Addiction Equity in Medicaid and CHIP

  12/04/2023

  Comments in support of the Centers for Medicaid and CHIP Services’ (CMCS) efforts to increase access to affordable, high-quality and culturally-competent mental health and substance use disorder services for patients covered by Medicaid and CHIP.

• PPC Comments RE: Requirements Related to the Mental Health Parity and Addiction Equity Act

  10/16/2023

  Comments supporting proposal to strengthen the standards for insurers and health plans to demonstrate that they are not imposing greater treatment limitations on enrollees’ access to treatments for mental health and substance use disorders (MH/SUD) than are applied to medical/surgical (M/S) treatment but urging the Departments to remove certain proposed exceptions, which threaten to undermine this important progress.

• PPC Letter to House Budget Committee RFI on Health Care Cost Containment

  10/15/2023

  Letter indicating that any efforts to reduce health care spending by Congress must ensure that insurance is accessible, adequate, and affordable for patients.

• PPC Letter to CMS RE Medicaid Unwinding and Additional Flexibilities

  10/10/2023

  Letter to Medicaid director thanking the Administration for recent efforts to reinstate Medicaid coverage for 500,000 children and adults and ensure that states fix errors in the renewal process.

• PPC Statement for Ways and Means Committee Hearing on Surprise Medical Bills and the No Surprises Act

  10/03/2023

  Statement supporting the No Surprises Act and expressing concern that amending the statute may destabilize the gains that have been made since its passage.

• PPC Comments RE: NPRM on Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Accident and Health Insurance

  09/11/2023

  Comments expressing strong support of this proposal, which would reduce the risk that products not subject to the insurance market rules of the Affordable Care Act (ACA) will be marketed and sold to consumers as a substitute for ACA compliant comprehensive coverage.

• PPC Comments RE: Request for Information Regarding Medical Payment Products

  09/11/2023

  Comments to HHS, Treasury, and CFPB regarding medical debt, junk plans and other challenges to ensuring health insurance is affordable, accessible, adequate.

• PPC Comments Re: Washington Medicaid Transformation Project Amendment

  09/08/2023

  Comments supporting Washington's waiver proposal to implement multi-year continuous eligibility for young children as a method to reduce negative health outcomes in Washington.

• PPC Statement on Medicaid Unwinding

  08/21/2023

  PPC statement urging that states use flexibilities in Medicaid to minimize unnecessary coverage losses, ensure lost coverage is reinstated as quickly and seamlessly as possible, and proactively notify beneficiaries of coverage reinstatements so that patients have access to the health care they need.

• Comments re: HHS Notice of Benefit and Payment Parameters Proposed Rule for 2024

  08/18/2023

  Letter requesting rulemaking to limit the sale and availability of short-term, limited-duration (STLD) health insurance

• PPC Letter to CMS re: Premiums in Medicaid

  08/18/2023

  Letter supporting elimination of premiums in the Medicaid program that go beyond those authorized in statute

• Leading Patient Organizations Call for Immediate Action to Protect Patients’ Medicaid Coverage

  07/28/2023

  Following the administration’s release of its first monthly Medicaid unwinding data report, patient organizations call for urgent, meaningful actions to address the unprecedented coverage losses occuring over the past few months.

• Letter to HHS RE: Patient Priorities for the Notice of Benefit and Payment Parameters Plan Year 2025

  07/27/2023

  Letter thanking the Administration for its ongoing efforts to ensure the effective implementation of the patient protections and consumer-focused policies of the Affordable Care Act (ACA) and offering input for future rulemaking for the 2025 plan year and beyond.

• PPC Comments RE: Illinois 1115 Behavioral Health Transformation Extension

  07/27/2023

  Comments supporting 1115 waiver application and Illinois' efforts to improve equitable access to quality and affordable health coverage.

• PPC Comments Re: Arkansas Health and Opportunity for Me (ARHOME) 1115 Amendment

  07/14/2023

  Comments strongly opposing Arkansas’ proposal to implement a complex new demonstration amendment that includes both work requirements and time limits for Medicaid beneficiaries as they will greatly threaten access to and continuity of care for Medicaid patients while creating additional barriers and implementation challenges within the ARHOME program.

• PPC Letter to the White House on Medicaid Unwinding

  07/10/2023

  Letter to the White House urging the Administration to take immediate action to protect Medicaid coverage for patients in states with high procedural termination rates.

• Patient Organizations Applaud Proposed Rule to Rein in Short-Term Plans

  07/07/2023

  Patient groups applaud the Biden Administration’s newly proposed rule designed to protect patients from short-term health plans, a rapidly growing form of low-quality health coverage.

• PPC Comments RE: Proposed Rule on Medicaid Program; Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality

  06/29/2023

  Comments supporting critical policies to improve access to care in Medicaid, including access and network standards, state directed payments, in lieu of services, and quality.

• PPC Comments RE: Ensuring Access to Medicaid Services

  06/29/2023

  Comments supporting policies to improve access to Medicaid for individuals with chronic illness and to empower the voice of enrollee stakeholders and offering recommendations to strengthen the proposed rule.

• Comments on a Proposed Rule Clarifying Eligibility for a Qualified Health Plan Through an Exchange, Advance Payments of the Premium Tax Credit, Cost-Sharing Reductions, a Basic Health Program, and for Some Medicaid and Children's Health Insurance Programs

  06/23/2023

  Comments supporting clarification that young people granted deferred action under the Deferred Action for Childhood Arrivals (DACA) policy are eligible to enroll in critical federal health coverage affordability programs

• Letter to House Leadership re: the detrimental impact of policies included in HR 2868, the Association Health Plans Act; HR 2813, the Self-Insurance Protection Act, and HR 3799, the CHOICE Arrangement Act

  06/21/2023

  Letter opposing policies included in about the detrimental impact of policies included in HR 2868, the Association Health Plans Act; HR 2813, the Self-Insurance Protection Act, and HR 3799, the CHOICE Arrangement Act

• Letter to House Energy and Commerce Committee Leadership re: the detrimental impact HR 824, the Telehealth Benefit Expansion for Workers Act

  06/21/2023

  Letter opposing policies included in HR 824, the Telehealth Benefit Expansion for Workers Act

• Letter to House Education and Workforce Leaders re: Concerns about detrimental impact of policies included in HR 2868, the Association Health Plans Act; HR 824, the Telehealth Benefit Expansion for Workers Act; and HR 2813, the Self-Insurance Protection Act

  06/06/2023

  Letter opposing policies included in HR 2868, the Association Health Plans Act; HR 824, the Telehealth Benefit Expansion for Workers Act; and HR 2813, the Self-Insurance Protection Act

• Comments re: Alabama 1115 Substance Use Disorder Demonstration Proposal

  06/02/2023

  Comments supporting efforts to address substance use disorder and encouraging the state to expand Medicaid.

• PPC Letter to HHS and CMS re: Medicaid Unwinding

  05/31/2023

  Letter urging HHS and CMS to take immediate action in response to Medicaid unwinding coverage losses.

• Comments to Arkansas Medicaid Program on ARHOME 1115 Amendment

  05/23/2023

  Letter opposing the ARHOME 1115 Amendment that would implement work requirements and time limits for Medicaid.

• PPC Statement: Patient Organizations Concerned by the Loss of Health Coverage for Nearly 75,000 Arkansans

  05/11/2023

  PPC statement on Medicaid Unwinding coverage losses released by Arkansas.

• 30 Patient Organizations Oppose Legislation Threatening Healthcare for Millions of Patients

  04/28/2023

  This legislation is a clear attack on access to quality and affordable healthcare with particularly devastating consequences for patients with serious, acute and chronic illnesses. We urge Congress to reject this bill. 

• PPC Statement for the House Committee on Education and the Workforce Subcommittee on Health, Employment, Labor, and Pensions Hearing on “Reducing health care costs for working Americans and their families”

  04/26/2023

  Statement fora hearing on reducing health care costs, which expresses concern about Association Health Plans(AHPs) and telehealth as an excepted benefit.