Last month, DPC sent a letter commenting on the “Notice of Benefit and Payment Parameters for 2017” proposed rule. This annual rule by the Centers for Medicare and Medicaid Services (CMS) contains proposed changes to the exchange plan coverage of the Affordable Care Act. DPC’s letter focuses on the importance of insurance coverage and network quality for end-stage renal disease (ESRD) patients.
One issue the letter comments on pertains to network adequacy. Network adequacy describes an insurance plan’s ability to provide a sufficient amount of in-network providers to subscribers in the plan. Suggestions to improve network adequacy include requiring all states to conduct network adequacy reviews with a set list of standards, and fixing any flaws in insurance plans before they are made available to consumers. Another concern regarding the adequacy of some exchange plan coverage is the exclusion of specialists that ESRD patients need for treatment, such as nephrologists.
Secondly, restrictive networks can lead to above average travel times for dialysis patients. DPC asked CMS to adopt a standard from California that requires a care site to be within 15 miles or 30 minutes from an enrollee’s residence or workplace.
DPC also stressed that private insurance plans must remain available for ESRD patients. According to data from DPC’s July 2015 patient survey, patients with private plans were better able to access the health care they needed. The full comment letter is available to read here.