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  • HIVMA Comments on Proposed Regulations for "Patients' Bill of Rights" Provisions

    HIVMA Chair, Mike Saag, MD, submitted public comments on behalf of HIVMA, regarding proposed implementing regulations for the “Patients’ Bill of Rights” provisions of the health care reform law. Private health insurance market reforms addressed in this regulation include:

    • Prohibition against preexisting condition exclusions
    • Prohibition against lifetime health insurance coverage limits
    • Restriction of annual coverage limits
    • Limitation on rescissions
    • Provisions guaranteeing direct access to certain types of providers and access to out-of-network emergency care

    Most of the reforms covered by these regulations go into effect on September 23, 2010, except for the preexisting condition exclusion, which goes into effect only for children under age 19 at this point, becoming effective for adults in 2014.  Also, the restriction on annual dollar coverage limits is phased in, becoming fully effective only in 2014.  A detailed summary of the proposed rule can be found on the Health Affairs website.

    HIVMA’s comments focus on the importance of ensuring access to HIV clinicians by requiring plans to contact with HIV clinicians and allowing patients to designate an HIV clinician as their primary care provider; and, the problem of continued permissibility of categorical exclusions of coverage for specific conditions or diseases.

    Read the full comments [PDF]  PDF

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