Documents

PPC Documents, Letters and Statements

• PPC Comments RE Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2026; and Basic Health Program (CMS-9888-P)

  11/12/2024

  PPC Comments to the Department of Health and Human Services thanking the administration for its steadfast commitment to improving the accessibility, affordability, and adequacy of care for all patients and expressing confidence that the policies included in the proposed rule will advance these shared goals. 

• PPC Comments RE: Louisiana Reentry 1115 Demonstration

  11/08/2024

  PPC comments supporting Louisiana’s thoughtful proposal and phased approach to implementing pre-release services for the justice-involved population and urging CMS to approve the demonstration. 

• PPC Comments RE: Michigan Reentry 1115 Demonstration

  10/31/2024

  Comments urging CMS to approve Michigan’s Reentry 1115 Demonstration proposal to provide pre-release services to the jusice-involved population and improve equitable access to quality and affordable health coverage in the state. 

• PPC Comments to Ways & Means Committee RE: Response to Request for Information – Tax Priorities

  10/15/2024

  Letter in response to Ways & Means Committee Request for Information on Tax asking Congress to permanently extend the Affordable Care Act’s (ACA) enhanced advance premium tax credits (APTCs) before they expire at the end of 2025 as permanently extending these critical subsidies is essential to preventing sudden increases in out-of-pocket costs and the loss of insurance coverage for millions of people.

• PPC Comments RE: Nevada Section 1332 Innovation Waiver Request

  09/25/2024

  PPC comments on Nevada's Section 1332 waiver proposal urging the Departments to work with the state to ensure that affordable and equitable access to care for all marketplace enrollees continues to be prioritized if this waiver is approved.

• PPC Comments RE: Maryland Section 1332 State Innovation Waiver Amendment Request

  09/20/2024

  PPC comments supporting Maryland’s proposal to use a Section 1332 waiver to allow all Marylanders, regardless of immigration status, to enroll in marketplace coverage and urging the Departments to approve it while encouraging the state implement a subsidy program that would improve affordability.

• Statement to House Education & Workforce Committee Leadership Re: Patient Community Concerns H.J. Res. 181, Congressional Review Act resolution to stop the Biden-Harris rule limiting access to Association Health Plans

  09/11/2024

  Statement urging urge the Committee to reject the resolution and, instead, partner with organizations like PPC to
  identify opportunities to expand affordable, accessible, and adequate healthcare coverage for patients.

• PPC Comments RE: Medicare hospital Outpatient Prospective Payment System (OPPS) and the Medicare Ambulatory Surgical Center (ASC) Payment System for Calendar Year 2025 Proposed Rule

  09/09/2024

  Comments supporting proposals from the Centers for Medicare & Medicaid Services (CMS), including: implementation of continuous eligibility in Medicaid and CHIP; the alignment of Medicare FFS prior authorization review timeframe for standard review requests for hospital outpatient department services with the timeframe in the Interoperability and Prior Authorization final rule; and targeted baseline health and safety standards for obstetrical services.

• PPC Comments RE: New York Section 1332 State Innovation Waiver: Amendment Application

  08/23/2024

  Comments supporting New York's proposal as a method to improve affordability of healthcare for lower income individuals in New York, as well as equitable access to care, while complying with the 1332 waiver statutory guardrails.

• PPC Letter to Congressional Leadership RE: The Need to Make Permanent the Enhanced Advanced Premium Tax Credits

  08/21/2024

  Letter from more than 40 patient and consumer groups urging Congress to take immediate action to permanently extend the enhanced advanced premium tax credits as people ​with serious and chronic conditions cannot afford to go without insurance that meets their healthcare needs. 

• PPC Comments to the Consumer Financial Protection Bureau RE: the Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information

  08/12/2024

  Comments strongly supporting the Bureau’s proposed rule prohibiting creditors from obtaining and using information on an individual’s medical debt when making credit determinations and offering recommendations to strengthen the prohibition and extend these critical protections to other uses of information regarding medical debt.

• PPC Comments RE: Iowa Health and Wellness Plan Extension Request

  08/11/2024

  PPC comments uring CMS to reject Iowa's proposal as it includes numerous harmful policies, including the continued imposition of premiums and healthy behavior requirements, copayments for non-emergency use of the emergency room, elimination of non-emergency medical transportation (NEMT), and elimination of retroactive coverage for most Medicaid beneficiaries. 

• Comments RE: District of Columbia Whole-Person Care Transformation Section 1115 Demonstration Renewal

  07/24/2024

  Comments applauding the District’s work to improve health equity in this waiver and supporting the inclusion of pre-release services for the justice-involved population and the waiver of cost-sharing requirements for medication-assisted treatment (MAT).

• PPC Comments RE: New York Medicaid Redesign Team Waiver

  07/24/2024

  Comments supporting continuous eligibility as a method to improve equitable access to consistent, quality healthcare in New York and we urging CMS to approve this proposal.

• Comments RE: Maryland Section 1332 State Innovation Waiver Amendment Request

  07/09/2024

  Comments supporting the proposal to expand access to quality coverage in Maryland and encouraging the state to consider implementing a subsidy program that would improve affordability of coverage.

• Letter to Members of the House of Representatives Committee on Appropriations RE: Policy Riders on the LHHS Appropriations Bill

  07/09/2024

  Letter urging Members of the House of Representatives Committee on Appropriations to actively oppose policy riders that are included in the fiscal year 2025 (FY25) Labor, Health and Human Services, Education and Related Agencies (LHHS) bill. These policy riders undermine key healthcare protections and make it even more difficult to pass vital funding bills.

• PPC Comments RE Rhode Island 1115 Comprehensive Demonstration

  07/03/2024

  Comments urging approval of the state’s request to establish 90-day pre-release coverage for justice-involved populations but denial of Rhode Island’s request to continue to waive retroactive eligibility. PPC urges CMS to require states to include all requested authorities in extension requests.

• PPC Comments Re: RFI for Nevada Battle Born State Plans and Market Stabilization Program

  06/28/2024

  Comments responding to questions from RFI on Nevada Battle Born State Plans and Market Stabilization Program encouraging policies to enhance health equity and quality.

• Patient Priorities for the 2026 Notice of Benefit and Payment Parameters

  06/07/2024

  Letter expressing appreciation for the administration’s commitment to improving the accessibility, affordability, and adequacy of care for all patients and are grateful for the hard work already undertaken to advance these shared goals, and offering recommendations for the 2026 Notice of Benefit and Payment Parameters (NBPP), as well as future rulemaking, including standards for web-based brokers and other direct enrollment entities, standardized plans, network adequacy, essential health benefits, transparency, and risk adjustment. 

• Partnership to Protect Coverage Members Request Meetings with Congress to Discuss Equitable Access to High-Quality, Affordable Healthcare Coverage

  05/21/2024

  PPC members conduct outreach to Congress to discuss options for expanding equitable access to high-quality, affordable healthcare coverage, including: (1) improving and expanding access to high-quality, affordable insurance coverage; (2) reducing the burden of medical debt on patients; and (3) protecting patients by limiting junk insurance.

• PPC Comments RE: Connecticut Substance Use Disorder 1115 Demonstration

  05/13/2024

  PPC comments supporting the proposed coverage for incarcerated youths and adults with additional health conditions who are otherwise eligible for Medicaid for up to 90 days prior to release, and requesting that CMS work with the state to ensure that existing state spending on healthcare for this population is supplemented, not replaced when implementing this policy. Comments also urge CMS to encourage Connecticut to clarify and eliminate cost-sharing requirements for this population for at least 12 months during their reentry period.

• PPC Comments RE: Colorado Substance Use Demonstration Amendment Request

  05/13/2024

  PPC comments supporting the state’s proposals to implement multi-year continuous eligibility for children under four, to add twelve-month continuous eligibility for adults exiting a Department of Correction facility, and to provide a targeted set of Medicaid services for justice-involved populations who are otherwise eligible for Medicaid for up to 90 days prior to release.

• 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.