Comment on CMS-2026-2081-0001

Center on Budget and Policy PrioritiesSupportAdvocacy
Summary: The Center on Budget and Policy Priorities (CBPP) supports a typicality standard for Essential Health Benefits (EHB) that allows states flexibility to select benchmark plans reflecting common employer coverage. They argue against using claims data to define typicality, oppose limiting EHB coverage for cost-control reasons, and urge CMS to reject restrictions on coverage for specific health conditions like gender dysphoria.
The Center on Budget and Policy Priorities appreciates the opportunity to comment on this Request for Information. See attached.

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