CDHP Comments on Essential Health Benefits Rule

The Children's Dental Health Project is pleased to share its comments in response to the HHS proposed rule on Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation. This rule provides guidance on the Affordable Care Act's (ACA) standard set of benefits that must be offered in the new state health insurance exchanges as well as the small group and individual insurance markets outside the exchanges. The rule also establishes standards for rating the value of these benefits and accrediting participating insurance plans. CDHP and many other children's health advocates, however, are concerned that the rule's treatment of stand-alone dental plans may undermine the law's intent and make these benefits unaffordable for some families.

Most importantly, we are concerned about the rule's proposal to establish a separate out-of-pocket maximum for stand-alone dental benefits which will result in higher out-of-pocket costs for families who choose or are forced to purchase their children's dental benefits separately from medical coverage. Additionally, we are concerned that the rule does not appropriately account for the cost of dental benefits in its standards for determining actuarial value as well as its interaction with rules related to premium tax credits. We urge HHS to provide clarification on these issues and ensure that families are held harmless regardless of how they purchase their children's dental coverage.

In addition to submitting comments, CDHP developed a sign-on letter echoing these concerns and was joined by 28 national and state-level organizations who are concerned about equity with regard to the essential health benefits and pediatric dental coverage. Both letters are available for download below.