'Essential Health Benefits' Memo to Advocates

On December 16, 2011, the Department of Health and Human Services (HHS), Center for Consumer Information and Insurance Oversight (CCIIO) issued a Bulletin providing preliminary guidance related to the implementation of the Essential Health Benefits (EHB) in the Affordable Care Act (ACA). The Bulletin reflects the HHS’ intent to balance the comprehensiveness, affordability, and state flexibility in final regulations by proposing to define the EHB by a benchmark plan selected by each State, similar to what is done in the Children's Health Insurance Program (CHIP). While we recognize the difficulty of determining how these services will be designed and administered in a manner that balances comprehensiveness, affordability, and state flexibility, the guidance raises some specific concerns related to the design of pediatric oral services requirement.

This memo to advocates provides background information and talking points in addition to analysis of proposed benchmark plans. The information provided is specifically designed for State advocates seeking additional guidance on how their State may implement the pediatric oral services portion of the EHB while mitigating potential risks to families who will be purchasing coverage. To view the memo in its entirety, please click on the above attached PDF.