Notice of Benefit and Payment Parameters for 2018 Comments

AAPCHO submitted these comments on the Notice of Benefit and Payment Parameters for 2018 to the Centers for Medicare and Medicaid Services (CMS) in October 2016. Our comments included language about the importance of requiring plans to provide notices/other essential documents in at least the top 15 languages by state, as well as the need to have a Federally Qualified Health Center (FQHC) as an essential provider within a plan’s service area.

Currently, CMS is asking plans to provide services in the top 15 languages by the total aggregate of states that a plan may provide services to, masking language differences by state (e.g., with Kaiser, if state language data were aggregated, Hawaii residents would not likely see resources in Ilocano, Laotian, Samoan, Marshallese, Trukese, Hawaiian, Micronesian, Bisayan, and Tongan, and Washington residents would lose access to several languages including Amharic, German, Cushite, Ukrainian, and Laotian).