Patient Protection and Affordable Care Act; Updating Payment Parameters (NBPP)


On behalf of the National Health Council, I am happy to offer the following comments on the Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond Proposed Rule (NBPP). 

Created by and for patient organizations 100 years ago, the National Health Council (NHC) brings diverse organizations together to forge consensus and drive patient-centered health policy. We promote increased access to affordable, high-value, sustainable health care. Made up of more than 140 national health- related organizations and businesses, the NHC’s core membership includes the nation’s leading patient organizations. Other members include health-related associations and nonprofit organizations including the provider, research, and family caregiver communities; and businesses representing biopharmaceutical, device, diagnostic, generic drug, and payer organizations. 

The NHC appreciates that CMS has issued this rule to improve Affordable Care Act (ACA) marketplace policy. We are particularly pleased to see that the proposed rule reverses various regulatory approaches that the NHC opposed when first presented. We also appreciate that the proposed rule codifies policies that will benefit patients. Our specific comments are below. 

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