By: Wayne Turner and Héctor Hernández-Delgado
Executive Summary
NHeLP urges the HHS Center for Consumer Information and Insurance Oversight (CCIIO) to reject the District of Columbia’s recent EHB benchmark plan update due to procedural defects. Specifically, the DC Department of Insurance, Securities and Banking and DC HealthLink announced a public comment period only days before the submission deadline, and closed that public comment period well after submitting its selection. Federal rules require states to provide reasonable notice and public comment for EHB benchmark selection so consumers and other stakeholders can provide meaningful feedback. If CCIIO were to approve DC’s PY 2026 benchmark update, it would set a terrible precedent and open the door for other states to circumvent engaging consumers and other stakeholders in EHB benchmark selection.
