ACS CAN Submits Comments to CMS on Proposed Marketplace Health Insurance Changes

Changes Likely to Impede Patients’ Access to Insurance; Increase Consumer Costs

March 7, 2017

Washington, D.C., March 7, 2016—Today the American Cancer Society Cancer Action Network (ACS CAN) submitted comments to the Centers for Medicaid and Medicare Services regarding proposed changes to marketplace health insurance plans. The submitted comments detail several ways the proposed ACA Market Stabilization rule could make it harder for cancer patients and survivors to access quality, affordable health insurance that meets their needs.

The comment letter states, “we are concerned that some of the policies that are proposed will actually impede a consumer’s ability to obtain health insurance coverage.” American Cancer Society evidence shows health insurance status has a direct impact on cancer outcomes and reducing access to such coverage would negatively impact our ability to reduce the cancer burden nationwide.

“ACS CAN supports a robust marketplace and welcomes efforts to strengthen the marketplace,” said Chris Hansen, president of ACS CAN. “However, those efforts should not jeopardize access to meaningful health insurance for cancer patients and survivors and those at risk for the disease.”

Specifically, the comments focus on the following areas:

Special Enrollment Periods (SEPs): Cancer patients often experience job loss due to their illness or must move to be closer to treatment or caregivers. These life changes don’t always happen during open enrollment. SEPs allow cancer patients in these situations to enroll in new coverage and maintain ongoing care. As proposed, increased restrictions on SEP enrollment, including pre-enrollment documentation requirements without concurrent marketplace determination deadlines and plan selection restrictions, could make it harder for cancer patients to maintain continuous care and could lead to needless delays or interruptions in patients’ treatment.

ACS CAN recommends a clear, expedited timeframe and appeals process for patients in active treatment as well as for those who have applied for coverage and are being denied treatment for a life-threatening illness because of their uninsured status.

Essential Community Providers (ECP): Cancer patients and survivors need to be able to access a wide range of medical services and specialties without paying high out-of-network costs. Proposed changes to essential community provider requirements could significantly reduce the number of in-network specialized cancer providers and limit patients’ ability to seek and afford the best possible care.

While reducing the percentage of ECPs required per plan could affect insurer’s costs, as stated in HHS’s Regulatory Impact Analysis, it would not reduce a consumer’s need to access such critical services and would leave patients with fewer choices. ACS CAN recommends HHS preserve the 30 percent ECP standard.

Actuarial Value: The proposed change to weaken the actuarial value of exchange plans would reduce a plan’s overall value to consumers while also diminishing the value of advanced premium tax credits for those who qualify. As acknowledged by HHS, allowing issuers to offer a less generous silver plan would increase consumers’, “exposure to financial risks associated with high medical costs,” and would make it harder for consumers to compare the value of plans in the same metal level. ACS CAN strongly urges HHS to maintain the current actuarial value standard.

ACS CAN, the nonprofit, nonpartisan advocacy affiliate of the American Cancer Society, supports evidence-based policy and legislative solutions designed to eliminate cancer as a major health problem. ACS CAN works to encourage elected officials and candidates to make cancer a top national priority. ACS CAN gives ordinary people extraordinary power to fight cancer with the training and tools they need to make their voices heard. For more information, visit


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