policy-comment70x70In comments submitted on January 31, 2012, NCCS offered advice to the Department of Health and Human Services (HHS) regarding the definition of essential health benefits (EHB) that must be offered by most individual and small employer health plans and certain public plans. NCCS urged HHS to strengthen certain elements of the essential health benefits package. The organization also recommended that HHS monitor the activities of states implementing essential health benefits standards to ensure that cancer patients relying on the package will have access to quality care.

NCCS offered its advice on a bulletin in which HHS outlined the general principles for essential health benefits, to be further delineated in regulatory action. The HHS approach would permit states great flexibility in determining the essential health benefits for plans offered in their borders. In its comment letter, NCCS urged that HHS be provided adequate resources for meaningful oversight of the state benefit packages, that there be limits on the ability of plan issuers to alter the essential health benefit package, and that HHS clearly define standards for those plans regulated exclusively at the federal level.

In addition, NCCS identified the special health care needs of cancer survivors and elements of an essential health benefits package that are critically important for survivors. NCCS urged incorporation in the essential benefits package of: 1) ten specific categories of benefits, 2) a prescription drug package that meets the needs of survivors, and 3) a clear definition of medical necessity to guide decisions about cancer patients’ access to care.

Finally, NCCS urged that HHS refine the essential health benefits package through a regulatory process that will permit additional public comment. NCCS intends to participate actively in ongoing efforts to define essential health benefits by submitting public comments and articulating the health care needs of cancer survivors.

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