Centers for Medicare & Medicaid Services
Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, DC 20201
Re: Comments on Proposed Rule on Patient Protection and Affordable Care Act; Health Insurance Market Rules; Rate Review [RIN 0938-AR40]
Dear Sir or Madam:
Young Invincibles is a non-profit, non-partisan organization that works to amplify the voices of young Americans and expand economic opportunity for our generation. As one of the leading organizations focusing on young adults and health care, we thank you for this opportunity to comment on the Health Insurance Market Rules. The important changes to the health insurance market will provide considerable protections to young people across the country. We urge you to take a few additional steps to ensure that this generation can take full advantage of the benefits offered by the Affordable Care Act. Specifically, we ask that HHS:
1. Adopt a broad definition of who will be included under family coverage;
2. Consider defining adult at a later age when starting age rating, if young adult enrollment proves to be at risk;
3. Include student health insurance in the broader risk pool, ensuring that the more uninsured, low-income young people and students who are not enrolled in colleges that provide insurance do not get unfairly harmed;
4. Take broader definitions of the primary care visits to be provided by catastrophic plans, and ensure that those visits 1) are available with no copay and 2) do not count against the preventive care coverage also provided.