BIO Comments on 2015 OPM Multi-State Plan Program Call Letter

On March 7, 2014, BIO submitted comments to the U.S. Office of Personnel Management (OPM) regarding OPM’s February 4, 2014 Multi-State Plan (MSP) Program Call Letter.

 BIO’s comments address the critical nature of the Affordable Care Act’s immunization coverage standard and comments on the following issues:

  • There is a critical need for OPM to ensure MSP compliance with the ACA’s “immunization coverage standard,” as this requirement is inextricably intertwined with the law’s requirements related to network adequacy;
  • In reviewing the adequacy of MSP provider networks under 45 C.F.R. § 800.109 to ensure compliance with ACA § 1334(c)(1)(B),2 in addition to those areas “where concerns have been raised about network adequacy,” OPM should ensure that MSPs include in their networks those provider types that furnish benefits promised under the ACA—including ACIP-recommended immunizations;
  • OPM should refine the applicable Essential Community Provider (ECP) standards by requiring MSPs to include in their networks all types of complementary immunization providers (i.e., pharmacy, public health department clinic, school-based clinic, or other community site) in each county in the MSP’s service area; and
  • OPM should stipulate that all Advisory Committee on Immunization Practices (ACIP)-recommended immunizations, whether provided in- or out-of-network, are covered and exempt from cost-sharing requirements, either in the final Call Letter for 2015 or in the standard contract with MSP issuers for 2015.