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pdfIndustry Comment Tracking
Last Updated: 10/28/2013
Relevant Section in
Original
Certification
Application
Relevant Language in Original Certification Application
POC
Summary of Comment
Timothy Dawson
N/A
N/A
What is done with the information? When I was signing my child up her
insurance was canceled because she had other coverage, but the coverage
is ending? Now she will have to go without insurance because of the misuse
of information. If there is to be no preexisting conditions, why would prior
previous information be necessary? When the information is not relevant
to a custodian, why would ACA allow home inspections if a child does not
reside with information giver. Seems to be many issues ACA has not
addressed and is a supposed law in effect of information
2
Timothy Dawson
Other/Policy
N/A
N/A
No comment seen on comment page and this sites states one comment? Timothy Dawson
“the Secretary will require a state to submit a Blueprint for approval and to
demonstrate operational readiness through virtual or on‐site readiness
reviews” The ACA website is not operational. If it doesn’t work now and it is
the law, how do we get health insurance? Rules conflict with COBRA law.
Ineligible for ACA coverage if divorced in last 6 months and COBRA requires
coverage eligibility for divorced statuses. No CAP on out of pocket costs per
executive order never updated since 03/2011 cannot help anyone
determine what the ACA will or will not cover, let alone if preexisting
conditions are or are not to be covered because of this. No contacts
available due to government shutdown. Why are government funds to be
used to track who has birth control coverage? Is birth control covered
under the ACA plans? Information not found.
Deny
Thank you, but this comment is outside of the
scope of the Blueprint Application.
3
Timothy Dawson
Other/Policy
N/A
N/A
What information is collected and shared with 3rd parties is a violation of Timothy Dawson
privacy. If me and my wife live in separate homes, file jointly and spend
more than ½ a year together, which information is used or shared with 3rd
parties? Do individuals have a right to live in their households? Who is
considered under household income when applying for individual ACA
benefits? Maybe I do not have a right to be married if I wanted to file jointly
with the IRS? The ACA does not allow eligibility for divorced individuals
within the last 6 months, yet COBRA law states my spouse/children are
entitled to their extended benefits if we were. No answers are available as
to where this information goes and which 3rd parties have access to it.
There are no ACA applications for entering 2 or more addresses for a
family? If filed individually they are not entitled to the same plans as a
family? Which possible home inspections are legal under the ACA due to
this information and in which home? If the systems do not accept individual
information like resident home addresses the systems are already wrong.
You have no way to validate the information when gathering techniques are
flawed to begin with. I cannot be responsible for flawed information
systems. Way to many flaws in the current ACA system to consider sharing
with 3rd parties, Especially when no contacts are available, many links do
not work and references are not available for the public to understand how
the information is to be used.
Deny
Thank you, but this comment is outside of the
scope of the Blueprint Application.
4
National Indian
Health Board
Other/Policy
2.2
The SHOP Marketplace has developed and implemented a The form suggests that this is an on‐going process, there are aspects of the Jennifer Cooper
stakeholder consultation plan and has consulted with, and form that contradict this assumption. For example, the state is expected to jcooper@nihb.org
will continue to consult with, employees, small businesses, indicate a date by which the consultation activity has been completed or it
agents/brokers, employer organizations, and other
expects to complete the activity. The form provides an HHS Benchmark of
relevant stakeholders as required under 45 CFR 155.130. August 1, 2013, for completion of this activity; however, it is not clear how
the benchmark is intended to be used. At the bottom of page 6, there is a
summary statement for Question 2.2 where the “State attests that this
activity is complete (Y/N).” While this follows the format for questions in all
the section, it also appears to undermine the idea that Tribal Consultation is
needed prior to the application, during the planning process, and during
implementation.
Comment
ID
1
Comment Type
(Burden,
Substantive,
Organization Name
Other/Policy)
Timothy Dawson
Other/Policy
Accept or
Deny?
Deny
Accept
CCIIO Response for PRA purposes
Thank you, but this comment is outside of the
scope of the Blueprint Application.
CCIIO will revise the language to make clear that
the consultation process is intended to be
ongoing. In addition, CCIIO will be revising its
Benchmark format and providing Blueprint
instructions to states which will make clear that
the process is intended to be ongoing and
collaborative.
1
Comment
ID
Industry Comment Tracking
Last Updated: 10/28/2013
Organization Name
Comment Type
(Burden,
Substantive,
Other/Policy)
Relevant Section in
Original
Certification
Application
Relevant Language in Original Certification Application
POC
Summary of Comment
If a state does not elect to conduct Outreach and Education, and only elects Jennifer Cooper
2.2
If a state has Federally recognized tribes: Tribal
to do Plan Management, the expectations are somewhat confusing. Item jcooper@nihb.org
Consultation: If electing to conduct outreach and
education activities, the State Partnership Marketplace, in 2.2 (page 48) states in part:
If not electing to conduct outreach and education activities, the State
consultation with the Federally recognized tribes, has
Partnership Marketplace participates in the Federally‐facilitated
developed and submitted to HHS a tribal consultation
policy and process. If not electing to conduct outreach and Marketplace (FFM) tribal consultation process related to applicable and
relevant activities and functions of the State Partnership Marketplace.
education activities, the State Partnership Marketplace
participates in the Federally‐facilitated Marketplace (FFM) In the past, we have not seen states participate in the FFM tribal
consultation process and we do not understand what that entails.
tribal consultation process related to applicable and
relevant activities and functions of the State Partnership Furthermore, if a state has received Establishment Grant funding to plan
their state‐based Marketplace or Partnership, then they should have an
Marketplace.
Exchange Tribal Consultation policy and they should be implementing it.
Accept or
Deny?
Deny
CCIIO Response for PRA purposes
This comment is not related to the burden of the
data collection. Additionally, states electing a State
Partnership Marketplace are no longer allowed to
conduct only Plan Management activities.
75
National Indian
Health Board
73
National Indian
Health Board
2.2, 2.3
If applicable: Tribal Consultation: If a state has Federally
recognized tribes, the Marketplace, in consultation with
the Federally recognized tribes, has developed and
submitted to HHS, a tribal consultation policy and process.
Jennifer Cooper
We hope that CMS will review the tribal consultation agendas and
jcooper@nihb.org
outcomes in question 2.2 to assure that the state engaged in tribal
consultation in development of their outreach and education plan for tribal
communities in question 2.3, including materials that address the special
benefits and protections for American Indians and Alaskan Natives in the
Marketplace and Insurance Affordability programs. However, we also note
that outreach and education is only one of many areas in which tribal
consultation will provide better outcomes for AI/AN and the I/T/U.
Deny
This comment is not related to the burden of the
data collection.
74
National Indian
Health Board
2.2, 2.3
If applicable: Tribal Consultation: If a state has Federally
recognized tribes, the Marketplace, in consultation with
the Federally recognized tribes, has developed and
submitted to HHS, a tribal consultation policy and process.
We want to underscore the importance of Tribes being involved in planning Jennifer Cooper
jcooper@nihb.org
and implementation of all aspects of the Marketplace, not just outreach
and education. For example, the I/T/U is affected by decisions made in Plan
Management related to such things as use of the Indian addendum for
provider contracts, network adequacy and payment by the federal
government for cost sharing reductions. State‐based Exchanges that have
included tribal representation on all of their workgroups, or created a
special Tribal workgroup, have designed Marketplaces that work much
better in relation to the I/T/U and serving AI/AN.
Deny
This comment is not related to the burden of the
data collection.
76
National Indian
Health Board
2.2, 2.3
CMS keeps trying to put Tribal issues under the umbrella of consumer and Jennifer Cooper
If a state has Federally recognized tribes: Tribal
stakeholder engagement, but the policy issues are much broader than the jcooper@nihb.org
Consultation: If electing to conduct outreach and
education activities, the State Partnership Marketplace, in outreach, education and enrollment topics that are typically on the agenda
for consumer engagement. Specifically, there are issues related to the
consultation with the Federally recognized tribes, has
distinctive Indian health care delivery system, and the I/T/U providing
developed and submitted to HHS a tribal consultation
policy and process. If not electing to conduct outreach and services and getting paid for those services.
education activities, the State Partnership Marketplace
participates in the Federally‐facilitated Marketplace (FFM)
tribal consultation process related to applicable and
relevant activities and functions of the State Partnership
Marketplace.
Deny
This comment is not related to the burden of the
data collection.
5
National Indian
Health Board
2.3a
The SHOP Marketplace has developed an outreach and
education plan that addresses outreach for each
population or type of stakeholder, including those
identified in 45 CFR 155.130, and metrics and criteria for
assessing impact of outreach and marketing efforts.
Deny
This comment is not related to the burden of the
data collection.
Other/Policy
We urge CMS to assure that the metrics proposed by the state include
outcomes for enrollment in relation to enrollment objectives for specific
population groups, including American Indians and Alaska Natives.
Jennifer Cooper
jcooper@nihb.org
2
File Type | application/pdf |
File Title | Marketplace Blueprint Comment Tracking Tool External Comments |
Subject | Marketplace, Blueprint, Comment Tracking, Tool, External Comments |
Author | CMS/Center for Consumer Information and Insurance Oversight(CCII |
File Modified | 2014-02-26 |
File Created | 2014-02-20 |