Comment on CMS-2026-2081-0001

Topic 1 – What counts as a "typical" plan States pick small group plans as the benchmark mostly because that data is easy to get, not because it's actually the best example of a "typical" plan. Big self-funded employer plans (which cover more people than small group plans do) barely get counted at all; that should change. A 10-person company and a 500-person company shouldn't be treated the same when deciding what's "typical." Topic 2 – Differences between states Every state having different rules is a real headache for brokers who sell in multiple states; they constantly have to ask "wait, why is this covered here but not there?" State differences can be good (they let states cover things their local population actually needs). We'd like a basic minimum set of covered benefits everywhere, with states allowed to add more on top; less confusion, still flexible. A simple public chart comparing what's covered state-by-state would save everyone a lot of work. Topic 3 – Cost/affordability The way employers and insurers actually control costs is through things like requiring pre-approval for certain treatments or using specific provider networks — not by just cutting benefits. Expensive drugs and behavioral health coverage are the biggest cost drivers we hear about. More generous required benefits = more government subsidy spending, so CMS should factor that in. Topic 4 – What should count as a required benefit Employers often offer extra stuff that isn't required (like adult dental/vision, fertility treatment, telehealth); CMS should look at that as a sign of what's "normal" now. The rules need to be more specific about what's included in a category (like "hospital services") so there's less arguing later. The current rules are based on old 2014-style plans and haven't caught up with things like telehealth Topic 5 – How often rules get updated Review the rules every 3–5 years automatically, but also allow updates sooner if something big changes (like a new expensive treatment). Give everyone (carriers, agencies) at least 12-18 months' notice before changes take effect; sudden changes cause chaos. Topic 7 – Rolling out any changes Roll out changes in phases, not all at once if at all possible...multi-state employer plans don't all run on the same calendar. Watch for warning signs like insurers pulling out of markets or rate spikes. Whatever changes, make sure there's clear, consistent messaging so brokers aren't caught off guard.