CMS Response to Public Comment Received for CMS-10285

CMS Response to Public Comment Received for CMS-10285

Comment: CMS received comments from an insurance industry advocacy organization recommending specific changes to the application.

Response: CMS appreciates the suggestions expressed by this commenter and addresses each item below.

Comment: The commenter suggested that CMS advise individuals in the introduction that the premium subsidy is available for up to nine months.

Response: While CMS understands the commenter’s wish to provide individuals with more information on the premium assistance itself, CMS purposely limited the background description to keep the form as simple as possible. CMS’s main goal in the introduction was to provide the minimum information necessary for each individual to determine whether he or she might be eligible for the premium and, if so, should direct his or her application to CMS or to the Department of Labor. A box in the introduction prominently identifies numerous means (e-mail, telephone, fax and website) for interested individuals to contact the premium assistance continuation coverage help desk and learn more about the program itself.

Comment: The commenter recommended that CMS enable individuals to file appeals electronically.

Response: Budget and resource allocations have restricted CMS’s ability to develop and implement an electronic version of this information collection package--especially given the tight turn-around time that enactment of ARRA in February 17, 2009 provided CMS to implement the entire expedited review process.

Comment: The commenter recommended that CMS require individuals requesting expedited review of denials of premium assistance to attest that they are signing their applications “under penalty of perjury.”

Response: CMS acknowledges the comment and has revised the application to require that attestation.

Additionally, CMS continued to simplify the introduction and instructions to make the documents more comprehendible. In order that the application be more consistent with that of the Department of Labor where necessary, CMS also made one or two other alterations (e.g., adding a separate section for individuals to provide information on plan sponsors).

Page 3 of 3