First Focus on Children joined the American Academy of Pediatrics, Children’s Defense Fund, and five other organizations in urging the Centers for Medicare & Medicaid Services (CMS) to substantially revise a proposed rule on benefit and payment parameters for 2027 in the Affordable Care Act Marketplace.
“We believe that insurance coverage for children must ensure access to timely, affordable, high-quality, and age-appropriate health care that meets their unique developmental needs and enables them to meet their full potential as adults,” the advocates wrote in their comment on the proposed rule entitled Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2027; and Basic Health Program. “Access to health care for children and their families is vital to long-term health, well-being, and productivity,” they continued. “While we share CMS’s goal of promoting program integrity and efficiency in the Marketplace, we believe the proposed rule must be substantially revised to ensure that children and their families – particularly children with chronic, complex, or serious health conditions – continue to have access to affordable and appropriate care.”
The joint comment outlines concerns that proposed rule changes could restrict access to affordable, comprehensive coverage, risking increased uninsured children and families. They oppose specific provisions including expanding catastrophic plans, raising out-of-pocket limits, increasing paperwork burdens, reducing network standards, certifying non-network plans, and eliminating standardized plan options. The organizations also highlight that the short 30-day comment period and lack of detailed regulatory impact analysis hinder thorough review and meaningful feedback.