Comments on CMS’s ‘Patient Protection and Affordable Care Act; Market Stabilization’

Brookings fellow Matthew Fiedler, a member of the Center for Health Policy and the Leonard D. Schaeffer Initiative for Innovation in Health Policy, submitted comments on the Center for Medicare and Medicaid Services’ (CMS) “Patient Protection and Affordable Care Act; Market Stabilization“.

An excerpt of his comment is below. Download the full comment here.

I welcome the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS) “Patient Protection and Affordable Care Act; Market Stabilization” notice of proposed rulemaking. This letter discusses two proposals contained in the proposed rule: (1) modifying the actuarial value de minimis range; and (2) implementing pre-enrollment eligibility verification for special enrollment period enrollees. Contrary to CMS’ stated objectives, both proposals are likely to reduce the number of people with insurance coverage and to harm, rather than improve, the individual market risk pool. The remainder of this letter discusses each proposal in turn. Please note that the views expressed in this letter are my own and do not necessarily reflect the views of other staff members, officers, or trustees of the Brookings Institution.