Mich. Insurance & Financial Services Department Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, Aug. 4 -- Michigan Insurance and Financial Services Director Anita G. Fox, Utica, has issued a public comment on the Centers for Medicare and Medicaid Services proposed rule entitled "Patient Protection and Affordable Care Act: Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond Proposed Rule". The comment was written and posted on July 28, 2021:

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Michigan appreciates the opportunity to comment on the proposed rule titled Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond ("Proposed Rule"), as published in the Federal Register on July 1, 2021.

The COVID-19 pandemic has underlined the importance of ensuring the accessibility of affordable, high quality health coverage for everyone, especially considering studies have shown that people with health insurance have better health outcomes. Throughout the pandemic, Michigan has advocated for enhanced enrollment opportunities. We welcome the administration's ongoing efforts on this front by offering the following comments in support of increased enrollment opportunities in the Proposed Rule.

Extended Open Enrollment

CMS requested comments on altering the open enrollment period so that it would begin on November 1 and end on January 15. Michigan believes that because of the ongoing challenges with the COVID-19 pandemic, extending the open enrollment period for this additional month is appropriate for this plan year. During the first year of the pandemic, we saw increasing unemployment rates, job shifting, and a corresponding loss of health coverage accompanying these changes. With an extensive outreach campaign in Michigan, we saw a nearly 2% increase in enrollment in Marketplace coverage during 2021 open enrollment. Michigan remains a willing partner to again help communicate about the affordable health coverage options available in the Marketplace during 2022 open enrollment. Allowing Michiganders extra time to enroll in coverage will help ensure people have access quality health coverage.

Monthly Special Enrollment Period for Household Incomes No Greater than 150% Federal Poverty Level

CMS requested comments regarding the establishment of a monthly special enrollment period (SEP) for enrollees with incomes no greater than 150% Federal Poverty Level (FPL). Michigan is appreciative of the SEP opened by the administration during plan year 2021. During this SEP, over 35,000 Michiganders have taken advantage of the opportunity to enroll in affordable health coverage they need for themselves and their families.

We must continue to do everything we can to ensure our most vulnerable residents have access to the coverage they need. As such, given the ongoing COVID-19 pandemic and the enhanced premium tax credits under the American Rescue Plan, Michigan supports the proposed SEP.

Michigan appreciates the opportunity to provide these comments.

Sincerely,

Anita G. Fox

Director

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The proposed rule can be viewed at: https://www.regulations.gov/document/CMS-2021-0113-0002

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