KCP supports insurance parity and coverage of treatment for individuals with kidney failure who purchase insurance through the Health Insurance Exchanges. Parity should mean that individuals in the Exchanges have the ability to maintain their private coverage for thirty months after diagnosis with kidney failure, a diagnosis that makes them eligible for Medicare. The Department of Health and Human Services (HHS) clarified in the Final Rule on the Establishment of Exchanges and Qualified Health Plans (CMS-9989-F) that MSP rules apply in the small group market.
Parity also means that individuals with kidney failure have the same access to tax credits and subsidies as do other Americans within the Exchanges. It also means that individuals with kidney failure enrolled in these plans are not discriminated against when it comes to having access to the providers, services, and items they need.
Given the importance of private coverage to the dialysis patient population, the Center for Consumer Information and Insurance Oversight (CCIIO) should maintain the federal commitment to Americans living with kidney failure by ensuring that coverage for ESRD is expressly included as an essential health benefit. Americans with life-threatening kidney failure should have access to coverage for ESRD in plans offered through the Exchanges.
KCP Comment Letters:
- Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2019 (November 27, 2017)
- Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2018 to Andrew Slavitt, Acting Administrator, CMS (October 6, 2016)
- Inappropriate Steering of Individuals Eligible for or Receiving Medicare and Medicaid Benefits to Individual Market Plans to Andrew Slavitt, Acting Administrator, CMS (September 22, 2016)
- 2017 Letter to Issuers in the Federally-Facilitated Marketplaces to Andrew Slavitt, Acting Administrator, CMS (January 15, 2016)
- Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017 Proposed Rule Letter to Andrew Slavitt, Acting Administrator, CMS (December 21, 2015)
- Nondiscrimination in Health Programs and Activities Proposed Rule Letter to Jocelyn Samuels, Director, Office of Civil Rights (November 6, 2015)
- Essential Health Benefits Proposed Rule Letter to Acting Administrator Tavenner (December 20, 2012)
- Essential Health Benefits Letter to Secretary Sebelius, Department of Health & Human Services (January 31, 2012)