ACHP Policy Library
ACHP plays an active role in the legislative and regulatory process. Below are policy-related documents and regulatory comment letters addressing issues from the Patient Protection and Affordable Care Act, Medicare, and Medicare Advantage.
The Patient Protection and Affordable Care Act
Patient Protection and Affordable Care Act
Exchange Eligibility - ACHP Comment Letter
ACHP prepared a response to the proposed rule on exchange eligibility. Following the proposed rules on governance, structure, and qualified health plans, CCIIO issued a proposed rule on exchange eligibility, which can be found here.
October 2011
Exchange Governance, Structure, and Qualified Health Plans – ACHP Comment Letter
ACHP prepared a response to the proposed rule on exchange governance, structure, and qualified health plans. In July, CCIIO issued this proposed rule, which can be found here.
October 2011
Risk Mitigation - ACHP Comment Letter
ACHP prepared a comment letter in response to the proposed rule on risk mitigation issued by CCIIO in July. The proposed rule and summary can be found here.
October 2011
Multi-state Health Plans - ACHP Response Letter
ACHP prepared a response to the request for information on multi-state plans issued by the Office of Personnel Management. The request for information can be found here.
September 2011
Premium Rate Review - ACHP Response Letter
ACHP prepared a response to NPRM issued for PPACA's premium rate review. The proposed rule and summary can be found here.
February 2011
Medical Loss Ratio - ACHP Comment Letter
ACHP filed this comment letter in response to the Secretary's Interim Final Rule on medical loss ratio. The interim final rule and summary can be found here.
January 2011
Accountable Care Organizations - ACHP Response Letter
The ACHP Medical Directors helped prepare this response to the CMS Request for Information on Accountable Care Organizations. The request for information, summary, and reports can be found here.
December 2010
Health Benefits Exchange - ACHP Response to the Request for Comment
ACHP prepared this response to the Secretary's Request for Comment. The request for comment, guidance, and reports can be found here.
October 2010
Internal Claims and Appeals and External Review - ACHP Response Letter
ACHP prepared this response to the interim final rule implementing the internal claims and appeals and external review provision in the ACA. The interim final rule can be found here.
September 2010
Grandfathered Health Plans - ACHP Comment Letter
ACHP commented on the grandfathered health plans interim final rule. The interim final rule and summary can be found here.
August 2010
Medical Loss Ratio - ACHP Response to the Request for Comment
ACHP prepared this response to the Secretary’s request for comment on medical loss ratio. The interim final rule and summary can be found here.
April 2010
Coverage to Age 26 - ACHP Early Implementation Letter
To avoid coverage gaps, ACHP members pledged to allow coverage of dependents to their 26th birthday before the September 23 implementation date. The early implementation request letter, interim final rule, and reports can be found here.
April 2010
ACHP – Comments on CY 2013 Medicare Advantage and Part D Proposed Rule
ACHP submitted comments on the CY 2013 Medicare Advantage and Part D proposed rule. The NPRM and a summary prepared by Health Policy Alternatives, Inc., can be found here.
December 2011
Bid Submission Process - ACHP Comments
ACHP prepared a response letter to the CMS request for feedback on the 2012 bid submission process.
August 2011
Medicare Advantage Advance Notice and Call Letter - ACHP Response
ACHP has prepared this response to the 2012 CMS advance notice and call letter. The advance notice and call letter can be found here.
March 2011
Proposed Rule - CY 2012 Medicare Advantage and Part D
ACHP prepared a response to the Medicare Advantage and Part D proposed rule for CY 2012. The proposed rule can be found here.
January 2011
ACHP Presentation – October 2011
This presentation was prepared for the October 2011 meeting of the ACHP Legislative Committee. The presentation provides updates on deficit reduction efforts, updates on state exchange implementation, and review of the proposed rule on Medicare Advantage and Part D.

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