September 23rd will mark the six-month milestone for the
Affordable Care Act and several provisions impacting children and families will
go into effect on that date including provisions in the “Patient’s Bill of
Rights” which:
o Prohibit employer or new individual health plans from
excluding coverage of specific benefits associated with a pre-existing
condition for any period of time and from denying coverage to a child based on
a pre-existing condition.
o Eliminate lifetime dollar limits and establish
restricted annual limits (until fully eliminated in 2014) for essential health
benefits in employer and new individual health plans.
o Allow a parent/guardian to designate a participating
pediatrician as their child’s primary care provider and require plans providing
emergency services to eliminate the need to prior authorizations, even when the
services are out-of-network.
At the end of June, the Obama Administration issued an
interim rule addressing how these provisions will provide important safeguards for families
in obtaining and utilizing health insurance for themselves and their children. CCF joined with American Academy of
Pediatrics, Children’s Defense Fund, Family Voices, First Focus, March of
Dimes, National Association of Children’s Hospitals and Related Institutions,
and Voices for America’s Children to recommend ways to make the protections
even stronger for families.
Specifically, the comments asked that revisions to the
interim rule ensure that:
o Families with sick children can truly obtain coverage
when they most need it, as envisioned by the pre-existing provision on the
health reform bill. This includes prohibiting insurers from establishing
unreasonable premium increases and/or excessive premiums for families with
children with pre-existing conditions. In addition, it is important that
guidelines be established for child-only plans establishing open enrollment
periods (as allowed under an advisory released
following in interim rule). Without rules on when and how these periods can be
applied, it will be difficult for families to access coverage when they most
need it; and
o Children can receive the services they need during the
phase in of the annual dollar benefit limits. Families with children,
especially those with special health care needs, may quickly hit the limits
proposed under the interim rule. It is important that the limits more
accurately reflect the experiences of these families and that the dollar limits
be raised. In addition, it is important that health plans be prohibited from
establishing non-dollar limits of families (e.g., restrictions on the number of
doctor visits).
In the coming weeks, we will post additional information
on the “September 23” reforms so check back in!