In soliciting comments, HHS asked what other data elements might be helpful to collect and requested input on whether closed block products or association products should play a role in defining a benchmark plan.
Public comments touched on several common themes: allowing each state to identify EHB will lead to a patchwork of benefits, the lack of information available on the limits in potential benchmark plans that could impede access to EHB, arbitrary limits will be used to restrict care, and the need for detailed information on prescription drug coverage.
Here are some of the comments posted on regulations.gov:
AARP, an interest group with 40 million members, is concerned that the state-by-state approach to identifying EHB will lead to "significant variability" in benefits among states. It wants data to be collected that includes the percentage of available drug products on a formulary, as well as the drugs subject to prior authorization, step therapy, or quantity limits. While it agrees with the decision to allow plans that meet NCQA or URAC standards to participate, the AARP wants assurances that the two organizations are "equally rigorous" to prevent health plans from venue shopping "for the easiest path to accreditation. To our knowledge, the processes of NCQA and URAC are not comparable."