Comments to the Centers for Medicare and Medicaid Services, Department of Health and Human Services, Proposed Interim Final Rule 45 CFR part 152, Pre-Existing Condition Insurance Plan Program, HIV Law Project and World PWN (2010)

On September 29, 2010, CHLP joined primary drafters HIV Law Project and WORLD/PWN in comments to the Department of Health and Human Services' Center for Medicare and Medicad Services on a proposed rule to define the terms of a new Pre-Existing Condition Insurance Plan Program that is a key element of the Obama administration's health care reform law. While many people currently excluded from private insurance will be able to secure coverage through these plans, there are several aspects of the program rules which threaten to make the plans inaccessible or inadequate for many people living with HIV, particularly women. In written comments also endorsed by AIDS Alabama, CHAMP and the Women's HIV Collaborative of New York., advocates identified several provisions in need of change: prohibitively high premium costs, restrictions on coverage of abortion and other reproductive health services, a mandatory six-month waiting period, the exclusion of HIV as a "presumed eligible" condition for plan eligibility, and an inadequate process for appealing denials of coverage.