Thread by @charles_gaba

🚨 UPDATE: The Public Comment period for the #NBPP2022 starts *TOMORROW* (12/04) and only runs 26 days (instead of 30) thru 12/30...including Christmas.

We need to flood 'em w/comments to stop Trump from trying to kill HCgov on his way out the door.

acasignups.net/20/12/02/updat…

The short version is this: Every year CMS issues a long, wonky document called the Notice of Benefit & Payment Parameters (NBPP), which is basically a bunch of tweaks to administrative details for the upcoming ACA Open Enrollment Period. 2/

Some of these are standard, like slightly bumping up the Maximum Out of Pocket cap for the following year. Some are good ideas, like adding a Special Enrollment Period for people who enrolled off-exchange but then have an income drop qualifing them for on-exchange subsidies. 3/

And then there's the controversial ideas, like when they talked about killing off #SilverLoading or Auto-renewals (fortunately they backed off of each).

This year, there's a dozen or so changes...most are fine, but three range from questionable to highly dangerous. 4/

1. First, after yrs of HCgov's user fee being arguably too high, it was reduced...but now they want to slash it even further, making it too LOW, which would reduce HCgov's budget by ~$520 million/year.

That's money which should be used for marketing, outreach, navigators, etc.

2. Second: Besides the official ACA exchanges, there's a couple dozen private Direct Enrollment web brokers authorized to hook directly into the ACA database. Nothing wrong with this--I'm a big fan of @healthsherpas, for instance--but let's just say the level of scruples vary.

As @TaraStraw noted last year, some EDEs don't display every #ACA plan, or push those from one carrier over another whether it makes sense for the enrollee or not...and others list #ShortAssPlans/Junk Plans side by side with ACA plans.
cbpp.org/research/healt…

Until now the rules/enforcement re. this sort of misleading behavior (which violates the EXACT REASON why the #ACA exchanges were created in the first place) were kind of fuzzy...but Trump's outgoing CMS Admin, Seema Verma, wants to EXPLICITLY ALLOW exactly this sort of thing.

3. Finally, Verma is pushing to go even beyond THAT by allowing individual states to opt out of using ANY #ACA exchange AT ALL. I don't mean moving to a state-based marketplace like @CoveredCA, @MNsure, etc...I mean *NO* exchange, period.

Needless to say, this is completely unacceptable for a variety of reasons.

Anyway, I'll be reposting this tomorrow w/a direct link for submitting public comment (and explaining why it makes a difference).