The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the proposed rule regarding Patient Protection and Affordable Care Act; Exchange Program Integrity . Medicare Rights is a national, nonprofit organization that works to ensure access to health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Medicare Rights provides services and resources to three million people with Medicare, family caregivers, and professionals each year.

The following comments are informed by our experience assisting beneficiaries, their family members, and health care professionals as they navigate selecting and accessing care through Medicare and the Marketplaces, including the Marketplace-to-Medicare transition.

We appreciate that the Centers for Medicare & Medicaid Services (CMS) is proposing this rule in an effort to strengthen Marketplace integrity, and as such is focused on coverage systems and mechanics. However, we are concerned that the agency’s close adherence to this perspective does not appear to allow for adequate consideration of how its proposal to terminate Marketplace coverage for certain enrollees would impact people with Medicare and those approaching eligibility.