Comment on FR Doc # 2010-18924

Document ID: HHS-OS-2010-0021-0006
Document Type: Public Submission
Agency: Department Of Health And Human Services
Received Date: September 29 2010, at 10:37 AM Eastern Daylight Time
Date Posted: November 4 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: August 3 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: October 4 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b632b2
View Document:  View as format xml

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As you know , Section 2706 Non Discrimination in Healthcare in the Affordable Care Act prohibits plans and insurers from discriminating against any provider acting within the scope of that providers license or certification under applicable state law. When composing uniformity standards, it is essential that all Exchanges adhere to this non discrimination standard, in order to avoid unnecessary confusion about coverage and guaranteeing a range of provider choices, to the good of the enrollee and the health care delivery system. A high Quality Healthcare Provider should provide high quality cost effective care. I believe in order to achieve this it is essential that a state level Exchange provides a wide range of certified providers, enabling consumers to choose the care that works best for them. An appropriate range of choices will also lower the cost of care, because non surgical and non pharmaceutical treatments , such as chiropractic care , have been proven to be effective and cost less than the traditional medical care. Further I believe that inclusion of more providers is an important step toward solving the provider shortage problem, particularly in the primary care sector , which is expected to be made worse by those newly covered as a result of the Affordable Care Act. I believe that providers should not be precluded from participation in an Exchange so long as they are practicing within the scope of their licensure. When establishing standards for participation of multi state plans in Exchanges, when different states have different benefits or provider standards, Exchanges should adopt the most inclusive standards. I think it is very important for states to insure that enrollees have access to the services currently available to them and are not threatened with the loss of health services that they value. And of course multi state plans must comply with the Sec 206 non discrimination provision.

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