AOTA Files Comments on Multi-State Plan Program Proposed Rule
AOTA submitted a comment letter on January 4, 2013 to the U.S. Office of Personnel Management (OPM) highlighting our position on coverage of habilitative services as an essential health benefit (EHB). OPM is required by the Affordable Care Act to contract with health insurance issuers to offer multi-state plans on health insurance exchanges throughout the country. These multi-state plans must cover the EHBs, and OPM will probably have to define how habilitative services should be covered by certain plans. Our OPM comment letter complemented our EHB comment letter.
However, because OPM’s proposed rule has a narrower scope as it pertains to the EHB issues that affect the profession of occupational therapy and its clients, the scope of our letter was also narrower. Essentially, our letter sought to argue that habilitative services should be covered as a distinct EHB, it should not be limited to a pediatric benefit, and parity between rehabilitative and habilitative services is an appropriate standard.
AOTA MSPP comment letter
