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Comments Supporting the Complete Rescission of the 2018 Association Health Plan Final Rule

The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Proposed Rescission of the 2018 Association Health Plan Final Rule. We applaud this full rescission of the final 2018 Association Health Plan (AHP) rule. Though the rule was never fully implemented, this rescission will eliminate any uncertainty regarding applicable definitions and standards.

The Affordable Care Act (ACA) guaranteed individual and small-group market consumers a basic set of benefits and protections, including a prohibition on discrimination in coverage based on preexisting conditions, limitations on pricing based on age, and access to essential health benefits. The 2018 rule, as finalized, would have allowed some employers to bypass these requirements and disproportionately burden people aged 50-64 through punitive pricing, discrimination, and inadequate benefits.

We commend the Biden-Harris administration for undoing this misstep and reaffirming valuable consumer protections.

Protect & Strengthen Medicare

Any changes to the Medicare program must aim for healthier people, better care, and smarter spending—not paying more for less. As policymakers debate the future of health care, we will provide our insights here.

30 Policy Goals

Thinking ahead to Medicare's future, it’s important to modernize benefits and pursue changes that improve how people with Medicare navigate their coverage on a daily basis. Here are our evolving 30 policy goals for Medicare’s future.

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