The Office of Patient Protection held a public hearing today to discuss their draft regulations of the open enrollment waiver process (see the regulations).
With just a handful presenting oral comments, the hearing lasted less than an hour. Kathy Bitetti and Bill Fields provided comment on the harm that open enrollment periods and limiting eligibility will cause to the individuals they represent: people who have multiple jobs, complicated income and need access to affordable insurance on the private market. Stephanie Richards from MAHP commented on the need to make sure carriers are involved in both the process of generating the waivers and that individuals only be able to get coverage from the carrier to whom they submitted the initial application. Paul Jones of BCBS commented on the need to make sure waivers are limited to those in extraordinary circumstances because of the intent of open enrollment. HCFA and HLA provided joint comments asking that the OPP be as compassionate as possible in implementing the waivers given the intent of both Chapter 288 and Chapter 58 – we want to make sure people can get the coverage they need when they need it. We also requested that the OPP re-evaluate the time frames in the regulation so that a waiver allows an individual to get retroactive coverage.
The OPP is still accepting written comments (submit as a Word document to: Reg.Testimony@state.ma.us and put “Health Insurance Waiver” in the subject line by January 14th at 5pm. The Department will post all electronic testimony that complies with these instructions on its website.
-Georgia J. Maheras