Today, APTA submitted comments to the Department of Health and Health and Human Services (HHS) in response to its December 2011 guidance bulletin, the Center for Consumer Information and Insurance Oversight's (CCIIO) January 27 bulletin, and the Institute of Medicine's (IOM) report titled Essential Health Benefits: Balancing Coverage and Cost. IOM's report reiterates that the determination of essential health benefits (EHB) should be based on a national standard of evidence-based medicine divorced from politics and policymakers' influence. Under the Affordable Care Act, rehabilitative and habilitative services must be offered in the states' affordable health care exchanges as a mandatory benefit in the basic health plan. HHS' secretary is tasked with further defining each mandatory category of services. APTA and other stakeholders have urged the secretary not to overly define the categories so that practitioners have the flexibility to provide both the type and frequency of care that is medically necessary for the individual.
Under HHS' intended approach, states have flexibility to use an existing health plan as a "benchmark" for the items and services included in the EHB package, choosing from among these 4 plans:
CCIIO provides a list of the products with the 3 largest enrollments in the small-group market in each state using data from HealthCare.gov.
Based on the states' ability to tailor the plans and consider adding optional services or increased numbers of visits, it is important that APTA's state chapters continue to educate and foster relationships with their state agencies to ensure that rehabilitative services are optimized in the plans.