On January 30, 2023, the National Women’s Law Center submitted a comment on the proposed Notice of Benefits and Payment Parameters for 2024, an annual rule by the Department of Health and Human Services (HHS) implementing various aspects of the Affordable Care Act. 

Among other recommendations, our comment urged HHS to: 

  • Ensure that all eligible individuals can receive Advance Premium Tax Credits (APTC) regardless of whether they have previously reconciled their credits when filing taxes 
  • Extend the timeline for consumers to resolve inconsistencies between self-attested income and IRS data, which disproportionately impacts households with low incomes, as well as require Exchanges to use self-attested income when IRS data is not available 
  • Adopt restrictions on non-standardized plans to make it easier for people to choose their health plan 
  • Strengthen requirements related to essential community providers (ECPs), which provide care for low-income and medically underserved communities, and establish new ECP categories for mental health and substance use services 

Our full comment can be found here.