HHS Proposed Rules on Exchange Implementation Requirements

Prepared for the Robert Wood Johnson Foundation

In an issue brief prepared for the Robert Wood Johnson Foundation's State Health Reform Assistance Network, Manatt's healthcare team highlights the key sections of the U.S. Department of Health and Human Services' proposed rules on the American Health Benefit Exchange implementation, released on July 11, 2011. While the regulations largely codify the Affordable Care Act (ACA) requirements, there are some notable exceptions. Embedded in the proposed regulations and in the commentary are several significant policy shifts that will impact state planning and implementation of Exchanges. The brief describes the provisions of the regulations and accompanying commentary that clarify the ACA and informs the collective thinking that has dominated the national discussion of Exchanges to date.



pursuant to New York DR 2-101(f)

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