APMA submitted comments to CMS on January 27 in response to the HHS Notice of Benefit and Payment Parameters for 2023 Proposed Rule. CMS proposed standards for issuers and marketplaces, as well as requirements for agents, brokers, web brokers, and issuers assisting consumers with enrollment through marketplaces that use the federal platform.
APMA’s comments addressed the proposed network adequacy reviews. The proposed rule incorporates APMA’s previous recommendations to require strong network adequacy requirements and enforcement to ensure that patients accessing health insurance through the Affordable Care Act Health Exchanges have access to care by podiatrists.
Additionally, APMA responded to CMS’ request for information to address health disparities. In its comments, APMA recommended that health plans impose similar cost-sharing on primary care and specialty care for patients with diabetes. This action would decrease costs and increase access to care by podiatrists for patients with diabetes.