Comment on CMS-2026-2081-0001
Blue Cross Blue Shield AssociationSupportTrade association
Summary: The Blue Cross Blue Shield Association (BCBSA) supports the current state-based Essential Health Benefits (EHB) benchmark plan framework and opposes moving toward a national benchmark or an actuarial value-based definition of typicality. They argue for preserving state flexibility while strengthening CMS enforcement of state defrayal obligations for mandated benefits that exceed the EHB.
The Blue Cross Blue Shield Association (BCBSA) appreciates the opportunity to provide comments in
response to the Centers for Medicare & Medicaid Services (CMS) Request for Information:
“Comprehensive Review of the Essential Health Benefits Framework and Typical Employer Plan
Standard” (CMS-9887-NC), published in the Federal Register on June 15, 2026. BCBSA submits these
comments on behalf of its member Blue Cross and Blue Shield (BCBS) Plans.
BCBSA is a national federation of independent, community-based and locally operated Blue Cross and
Blue Shield companies (Plans) that collectively cover, serve and support 1 in 3 Americans. BCBS Plans
contract with 97% of hospitals and 83% of doctors across the country and serve those who are covered
through Medicare, Medicaid, an employer, or purchase coverage on their own.
BCBSA’s detailed recommendations on the seven RFI topic areas are attached. We appreciate your
consideration of these comments. If you have any questions or require additional information, please
contact Sarah Heard at sarah.heard@bcbsa.com.