On January 8, 2024, the National Women’s Law Center submitted a comment on the proposed Notice of Benefits and Payment Parameters for 2025, an annual rule by the Department of Health and Human Services (HHS) implementing various aspects of the Affordable Care Act. 

Among other recommendations, we urged HHS to: 

  • Establish a permanent Special Enrollment Period for people with incomes up to 250% of the Federal Poverty Level 
  • Make pregnancy a qualifying life event that allows people to gain coverage outside of the open enrollment period 
  • Apply regulations related to web-brokers and direct enrollment platforms in both federal and state Exchanges 
  • Require states to offer standardized plans, which make it easier for people to choose their health plan 
  • Require all Exchanges to send an annual notice to consumers who have not reconciled their advance premium tax credits (APTC) when filing taxes, as well as to pause APTC denials until it fixes existing problems with ineffective and constitutionally unsound notices 
  • Mandate that all Exchanges accept enrollees’ self-attestation that they are not currently incarcerated, without requiring burdensome documentation to verify their status 
  • Strengthen Essential Health Benefit (EHB) coverage by setting national standards for each EHB category, clarifying when a state needs to defray the cost of added services, and revising the process for updating EHB benchmark plans 
  • Require more insurance plans to improve their provider networks by applying time and distance network adequacy standards to state Exchanges, as well as adopting a range of addition network adequacy standards across all Exchanges 

Our full comment can be found here.