American Association of Ancillary Benefits Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule
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The AAAB is a nonprofit trade association that services the ancillary benefits industry. The mission of AAAB is to advocate for the ancillary benefits industry on behalf of carriers, vendors, third parties, and distributors, as well as to advocate for specialty carriers, prepaid legal services, and other niche products.
AAAB will also coordinate ACA and Medicare issues for its members and other associations involved in this market, which includes agents and brokers. In addition to advocating for these matters, AAAB will also focus on thoughtful educational opportunities.
The AAAB has reviewed the aforementioned proposed rule and has significant concerns that the rule's wording could be confusing so CMS should provide clarification. In the executive summary it says:
We also propose to remove Sec. 155.221(j) and repeal the Exchange Direct Enrollment option which establishes a process for State Exchanges, State-based Exchanges on the Federal platform, and Federally-facilitated Exchanges to work directly with private sector entities (including QHP issuers, web-brokers, and agents and brokers) to operate enrollment websites through which consumers can apply for coverage, receive an eligibility determination from the Exchange, and purchase an individual market QHP offered through the Exchange with APTC and cost-sharing reductions (CSRs), if otherwise eligible.
This run-on sentence could be read in several ways. Talking to many association members who read this, they interpret it to mean that ALL direct enrollment is being eliminated.
However, in discussions with current and former CMS insiders, they are saying the intent is simply to eliminate the so-called "
Thank you for your time and consideration of this request.
Regards,
CEO
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The proposed rule can be viewed at: https://www.regulations.gov/document/CMS-2021-0113-0002
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