Oct. 25, 2011
The U.S. Department of Health and Human Services (HHS) is receiving comments from the public about proposed regulations for the new state-based health insurance exchanges and qualified health plans under the new health care reform law. NOW wants to make sure that women's access to insurance coverage for abortion care is made simple and affordable.
Take action NOW: Write your own comment or use NOW's sample comment below by cutting and pasting it into the appropriate space on the government regulations website. The deadline for comments is Oct. 31, so act NOW! Additional information is provided in the background section below.
Dear Secretary Sebelius:
RE: CMS-9989-P, Proposed Rule Regarding Establishment of Exchanges and Qualified Health Plans.
I am writing to urge that the U.S. Department of Health and Human Services take action in finalizing regulations for the state-based health exchanges and the qualified health plans under the Patient Protection and Affordable Care Act (ACA) to assure that women are made aware of the availability of insurance plan riders for abortion care and that ease of payment be facilitated. A single transfer of funds for payment of both the main policy and the rider should be permitted.
The training of personnel (navigators) associated with the health exchanges must include information about women's health needs, and at least one navigator in each exchange should be a community or consumer-focused non-profit entity. Further, I urge the department to adopt standards that allow for a broad array of specialists and providers, including women's health clinics where women can obtain obstetric/gynecological care as well as family planning services.
I also suggest that the department recognize that individuals in civil unions or registered domestic partners under state laws should be allowed to enroll. It will be important for the department to facilitate a strong oversight mechanism in the reviews of insurance rates, especially with regard to rates for abortion coverage. A strong prohibition against discrimination on the basis of color, national origin, age, sex, gender identity or sexual orientation is critically important. Women have suffered from discriminatory practices by insurers and, hopefully, the ACA will put an end to that. I am looking forward to a robust implementation of these and other safeguards and assurances for women under the ACA.
The Patient Protection and Affordable Care Act (ACA)[P.L. 111-148] contains many provisions that will give women and their families health insurance coverage and access to care. Insurance through state-based health benefit exchanges is set to be available in 2014, when an estimated 25 million persons formerly uninsured or under-insured will become eligible for coverage.
Among the many improvements of the ACA that will benefit women is the prohibition of denial of insurance coverage due to pre-existing health conditions. But a number of provisions are designed to complicate women's access to insurance coverage for abortion care. The regulations implementing the ACA must be drafted carefully to maximize the new law's benefits and to streamline access to critical health care services for women.
NOW has urged the department to adopt regulations that will lessen the impact of the ACA's restrictions on insurance coverage for abortion care. Remember that in order to pass the law, feminist allies in Congress were forced to accept an amendment requiring insurance companies to charge separately, by means of an abortion "rider," for coverage of abortion care. Currently, some 90 percent of private insurance plans cover abortion care, and the regulations need to be formulated to minimize the negative impact of the ACA's restrictions as much as possible.
NOW's comments sent in late September to Health and Human Services Secretary Kathleen Sebelius contained a number of key points:
1) HHS should allow qualified health plan issuers (insurance companies) to issue itemized bills for the main policy and the abortion care rider and to collect from each enrollee the separate payments through a single transfer of funds.
2) HHS should assure extensive public education and outreach activities so that women will be aware of the availability of the insurance rider for abortion care.
3) HHS should adopt standards that would require insurers to make available a wide array of specialists and providers, including women's health centers -- particularly those that specialize in primary health care, and routine gynecological and obstetrics as well as family planning services.
4) The training of personnel ("navigators") associated with the health exchanges should include information about women's health needs, and at least one navigator in each exchange should be a community or consumer-focused non-profit entity.
5) The department should recognize the right of individuals in civil unions or those registered as domestic partners to enroll.
6) Review of insurance rates should carefully monitor charges for the abortion care insurance rider so as to assure that amounts do not become excessive.
7) Non-discrimination standards should be applied across the board to truly eliminate the practice of charging women higher rates than men for the same coverage.
Many other recommendations are included in NOW's full comments.
Review the proposed regulations
Please send your comments to HHS as soon as possible -- the deadline is Monday, Oct. 31.
Take action NOW!