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AMSA Speaks to HHS on Essential Health Benefits

Colin McCluney

Education & Advocacy Fellow

Hello fellow AMSAns! On Tuesday, AMSA was invited to give comments to the Department of Health and Human Services (HHS) on the process and criteria for defining the Essential Health Benefits (EHB) to be covered by plans in the insurance exchanges established by the ACA. I had the privilege to offer remarks on behalf of AMSA based on our Preamble, Purposes and Principles (or PPP). The PPP is the Association’s guiding document as approved by our members through the House of Delegates (HOD). You can download the PPP online and learn more about submitting resolutions to the HOD if you feel that something is missing.

During the listening session, I was able to speak from the podium and gave these brief remarks. This is the first step of our involvement in the process of defining EHBs – additional opportunities for comment will take place after HHS issues its proposed rules. I look forward to continuing to participate in this and will be sure to keep you informed of the progress!

If you have any questions or comments, please feel free to contact me!

Remarks to the Department of Health and Human Services on Essential Health Benefits to be offered under the insurance exchanges:

My name is Colin McCluney; I am the Education and Advocacy Fellow at the American Medical Student Association. AMSA is the oldest and largest independent association of physicians-in-training in the United States, representing over 36000 members.

The American Medical Student Association believes that comprehensive health insurance coverage includes but is not limited to primary care, preventive services, reproductive services, acute & chronic care services, dental care, mental health & substance abuse treatment, prescription drugs & medical supplies, ophthalmic care, palliative & end-of-life care, physical & occupational therapy, hearing care and language access services. Services covered as essential health benefits should be determined using an evidence-based methodology. The core of the IOM’s criteria address this well, stating that the benefit must be safe, medically effective, must demonstrate meaningful improvement, and be cost-effective.

We reject the notion that cost should outweigh coverage in the EHB; skimpy benefits packages simply transfer the costs of care to individuals, continuing the trend of medical bankruptcies and patients avoiding medically necessary care. In addition to further burdening individuals and their families, delayed care will lead to higher costs to the system.

Value-informed insurance design is a model of plan design which accounts for patient heterogeneity, encouraging the use of cost-effective services and discouraging services in which the benefits do not justify the costs. This model is preferable to the IOM's cost-first model in its attention to individual patient needs, addressing the risk of underuse inherent in a cost-first model. Patients are supported with low co-pays in accessing high-value care and the results are cost-savings and increases in patient compliance.

We particularly want to emphasize the importance of coverage of mental health, ensuring adequate access as well as coverage which may require standards exceeding parity with physical health. We also encourage the inclusion of patient education by health care providers as essential coverage. Supporting a reimbursement model that values the importance of the patient-physician relationship can improve patient compliance & understanding leading to improvements in individual and population health.

Finally, we would like to note that while state flexibility may help to drive innovation, strong federal requirements need to be maintained to ensure adequate coverage.

In summary, the American Medical Student Association supports a comprehensive package of essential health benefits that puts patients first; we support innovation in plan structure, such as value-informed insurance design; and we encourage strong federal requirements for state compliance. Thank you for your time.

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