Dear HHS, Remember Women are Essential. Love, RWV.

On Friday, the U.S. Department of Health and Human Services (HHS) issued its first pre-rule bulletin on the Essential Health Benefits (EHB) provision of the health reform law.  

To meet the EHB requirements states will have to ensure that all insurance plans offered through the insurance exchanges cover the minimum set of benefits established by the law, including the 10 categories of care, like comprehensive maternity care and preventive health care that Congress laid out. The Friday bulletin from HHS says that states will be allowed to choose from several options to set up a benchmark plan, and the benefits offered under that plan will be the starting point for the state’s EHB.  A state might choose as its benchmark plan:

• One of the three largest small group plans in the state;
• One of the three largest state employee health plans:
• One of the three largest federal employee health plan options;
• The largest HMO plan offered in the state’s commercial market.

States that are hard at work creating exchanges were glad to get some direction about this important issue from HHS, and RWV is pleased that the process continues to move forward.  But health justice and women’s health advocates still have a lot of questions about what this approach will mean for people’s ability to get meaningful health care coverage, as promised by the health reform law.  We’re concerned that the approach outlined in the bulletin allows states so much flexibility that it won’t fix the problems women have been struggling with in states where high quality services are not accessible at an affordable price.

Strong federal standards for the EHB are essential to ensuring that health reform fulfills its promise to women of access to a core set of health services we need to stay healthy.  The EHB provision was supposed to correct longstanding gaps in coverage that many women currently face.  We are counting on HHS to uphold these promises by providing states with specific and enforceable direction.

HHS has requested comments on the bulletin by the end of January.  RWV plans to hold a series of calls to gather input on its strengths and on the issues that still need to be addressed before writing and submitting our comments.  To be part of this process, sign up for our newsletter to receive more information in the new year!