The group also is concerned about making network adequacy a part of the accreditation process. AARP views that as a regulatory function. "No plan should be allowed to participate in the exchange with an inadequate network, regardless of how well it does on other aspects of accreditation."
The Cancer Action Network, the advocacy arm of the American Cancer Society, argues that "arbitrary and unreasonable limits (in [potential benchmark plans) could be used to restrict needed care" and may be inconsistent with healthcare reform's "clear intention to guarantee that at least the 10 benefit categories are covered." The group is concerned that the medical benefits template for individual family plans included a question about diabetes wellness plans. "We want to ensure that wellness programs, which are not actually benefits, are not included in the EHB."
The network recommends that each health plan submit its definition of medical necessity, which it says can vary widely among plans.
The American Federation of State, County & Municipal Employees, which represents 1.6 million members and retirees, wants HHS to collect data on rider policies made available by a health plan. "High enrollment in a plan can be attributed, at least in part, to the availability of rider policies" and is information HHS needs to develop policy that reflects the ACA requirement that EHB reflect a typical employer plan.