Children require greater essential health benefits through health reform

Beginning in 2014, typical health insurance plans must cover certain services and benefits to customers — a victory for children and families won through health care reform. Today Voices for America’s Children responded to the U.S. Department of Health and Human Services’ (HHS) “Essential Health Benefits Bulletin.” HHS issued the bulletin last month in order to define “Essential Health Benefits” for implementation of the Affordable Care Act and the new health insurance exchanges.  Check out our comments here.

Ensuring a robust and comprehensive Essential Health Benefits (EHB) package is critically important for children, especially those who are lower-income and/or have special health care needs.  HHS must aggressively define the EHB package for children and cannot rely on the sufficiency of the existing benchmark options outlined in the bulletin. This is especially relevant to the pediatric services outlined in the bulletin, such as oral and vision care.

Voices recommended the following regulatory approaches:

• HHS should take a prescriptive, rather than flexible, approach in setting the standard for children’s health care.
• Valuable state mandates securing access to critical services for children should be included in the EHB definition.
• Centers for Medicare & Medicaid Services must clarify its regulations on the Children’s Health Insurance Program dental benefit as required by its renewal legislation in 2009.
• It is important to provide detailed regulatory guidance to states on the design of the pediatric dental benefit.
• Ensure that the Exchange regulations provide consumers equitable affordability of oral health benefits, regardless of issuer.
• HHS should allow and encourage states to provide cost‐effective risk‐based pediatric dental benefits.
• Medicaid’s pediatric standard of coverage, EPSDT, should serve as the model for the scope and breadth of EHBs for children, including vision/oral care.  This includes EPSDT’s broader medical necessity definition, which is critical to ensuring healthy childhood development.
• The outlined approach regarding potential benchmarks for pediatric oral and vision care should be strengthened, so that states have the option of using the children’s Medicaid benefit as a benchmark.

We look forward to working with HHS to implement these recommendations, in order to ensure all children receive quality health care coverage and access as a result of the Affordable Care Act.