Submitted by email to GIB’s Liaison Officer on March 13, 2018
AN OPEN LETTER TO MEMBERS OF THE GROUP INSURANCE BOARD
At GIB’s 21 February 2018 meeting, ETF staff presented a document titled “Health Benefit Program Agreement & Uniform Benefits for the 2019 year.” This letter focuses on the “Pharmacy Benefit Change Concepts” outlined on pages 6 and 7 (see Attachment A below) and urges all members of the GIB to investigate thoroughly each of the issues raised below before endorsing any of these “benefit change concepts.” GIB members have a fiduciary responsibility to act “prudently.” “Prudence” implies not only “caution” and “due-diligence” but more broadly, the capacity for judging in advance the consequences of one’s actions and decisions. Without a thorough understanding of the issues raised below, “prudent” action and decision-making are impossible.
Re: Proposed “Carve out [of] Pharmacy Uniform Benefit language from the GHIP Agreement.”
Would a “de-linked” and “carved-out” pharmacy health plan STILL be subject to Federal Affordable Care Act (ACA) coverage requirements and non-discrimination protections? (For example, would ACA’s list of required “essential health benefits” still apply? What about ACA’s protections for “pre-existing medical conditions” or current prohibitions on charging women higher premiums than men?) . . .
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