Ascension Health--DC

Dear Ms. Tavenner: Ascension Health welcomes the opportunity to submit comments for “Patient Protection and Affordable Care Act; Establishment of Exchanges and Qualified Health Plans; Small Business Health Options Program” proposed rule. Ascension Health is the nation's largest nonprofit and Catholic healthcare delivery system, with over 1,500 health facilities and 118 hospitals in 23 states and the District of Columbia. As a Catholic healthcare ministry, we are committed to helping the poor and most vulnerable populations by providing them with the best care. Since 2011, Ascension Health has embarked on a small business advocacy campaign where we educated over 5,000 individuals on the benefits of the Affordable Care Act (ACA) and on the Law’s positive impact to small business. Many of the 5,000 individuals we educated were small business owners who expressed to us their support of giving their employees a choice among multiple insurance plans and of an employer-friendly payment process. In their eyes, these two features were the biggest benefits of the Small Business Health Options Program (SHOP) under the ACA. Delaying their implementation as proposed would be detrimental to many small business owners. Ascension Health understands the proposed rule would only delay employee choice and the premium aggregation function for one year. However, these are key features to distinguish the SHOP from the outside small group market and delaying their implementation would undermine the goal of attracting employers to participate in the SHOP. Ascension Health urges CMS to reconsider the proposed delay and implement the employee choice and associated premium aggregation provisions that were finalized in the “Exchange Establishment Rule” (77 FR 18310). Beginning in 2014, those regulations codified the Affordable Care Act (section 1312(a)(2)) to require that the SHOP provide an opportunity for qualified employers to choose a level of coverage and then offer qualified employ