January 16, 2024

APMA submitted comments to HHS last week, responding to HHS’ proposed rule, “Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2025; Updating Section 1332 Waiver Public Notice Procedures; Medicaid; Consumer Operated and Oriented Plan (CO-OP) Program; and Basic Health Program.”

APMA focused its comments largely on HHS’ proposal to not require State Exchanges and State-Based Exchanges on the Federal Platform (SBE-FPs) to enforce the appointment wait time standards and ensure that the provider network of each QHP (qualified health plan) meets applicable standards specified in 45 CFR §156.230(b) through (e), for 2025. APMA believes that strong network adequacy ensures that the most vulnerable patients, especially those living in rural and small communities, continue to receive access to the critical medically necessary foot and ankle care provided by a doctor of podiatric medicine, and as such, it is critical to require State Exchanges and SBE-FPs to adhere to these requirements.

Members can read this letter in full, as well as others, at www.apma.org/commentletters. If you have questions or concerns, contact the APMA Health Policy and Practice department at healthpolicy.hpp@apma.org.