policy

January 25, 2018

Assistant Secretary for Planning and Evaluation
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201

Sent via CompetitionRFI@hhs.gov.

Re: ACAP Response to Department of Health and Human Services: Promoting Health Care Choice and Competition Across the United States

To Whom It May Concern:

The Association for Community Affiliated Plans (ACAP) is pleased to submit comments in response to the Department of Health and Human Services’ (HHS) Request for
Information, Promoting Health Care Choice and Competition Across the United States. ACAP represents 61 not-for-profit, community-based Safety Net Health Plans located in 29 states. Our member plans provide coverage to 20 million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP), and Medicare Advantage Dual Eligible SNPs, and qualified health plans in the individual Marketplace. Nationally, ACAP plans serve almost half of all Medicaid managed care enrollees.

The Request for Information issued by the office of the Assistant Secretary for Planning  and Evaluation (ASPE) on December 26, 2017 asked for input by the public on a number of questions related to Medicare, Medicaid, and other sources of payment, with an emphasis on choice and competition, and reducing regulatory burden. We focus our responses on programming related to Medicaid and also coverage of individuals who are dually eligible for Medicaid and Medicare. At ASPE’s request, our letter does not address our views on Association Health Plans, Short-Term Limited Duration Insurance, and Health Reimbursement Accounts. ACAP has commented to HHS on these issues in a separate communication.

This RFI lays out five distinct questions:

1. What State or Federal laws, regulations, or policies (including Medicare,
Medicaid, and other sources of payment) reduce or restrict competition
and choice in healthcare markets?

2. What State or Federal laws, regulations, or policies (including Medicare,
Medicaid, and other sources of payment) may promote or encourage
anticompetitive behavior in healthcare markets?

3. What State or Federal grants or other funding mechanisms (including
Medicare, Medicaid, and other sources of payment) reduce or restrict
competition and choice in healthcare markets?

4. What State or Federal grants or other funding mechanisms (including
Medicare, Medicaid, and other sources of payment) may promote or
encourage anticompetitive behavior in healthcare markets?

5. What suggestions do you have for policies or other solutions (including
those pertaining to Medicare, Medicaid, and other sources of payment) to
promote the development and operation of a more competitive healthcare
system that provides high‐quality care at affordable prices for the
American people?

ACAP provides our comments below, organized by program.

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