ACS CAN Comments on Short-Term proposed rule
On April 20, 2018, ACS CAN filed comments on the proposed rule amending the definition of short-term, limited-duration (STLD) insurance for purposes of its exclusion from the definition of individual health insurance coverage. We expressed concern about policies that would expand access to STLD policies because these products are exempt from important consumer protections, such as prohibitions on lifetime and annual dollar limits, limits on the use of pre-existing condition exclusions, and the prohibition on medical underwriting. These protections are key to ensuring that individuals with cancer (including those in active treatment and survivors) have access to quality health care needed to treat their disease. Without these protections, individuals could find themselves enrolled in policies that fail to provide coverage of medically necessary services. We believe this proposed rule should be withdrawn unless the needs of the patient community have been met, as discussed in more detail in our comment letter.