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American College of Rheumatology Responds to Short-Term, Limited-Duration Insurance Proposed Rule

Rheumatology Leaders Caution Expanding Short-Term Plan Availability Could Weaken Consumer Protections, Create Confusion Among Patients

Washington, D.C. – In comments submitted to the Centers for Medicare and Medicaid Services (CMS), the American College of Rheumatology (ACR) expressed concern that the Short-Term, Limited-Duration Insurance (STLDI) proposed rule could weaken consumer protections that enable individuals living with rheumatic diseases to access quality, affordable care.

The ACR expressed that increasing the duration of short-term plan coverage from three months to twelve could make it more difficult for some consumers to distinguish short-term gap coverage plans from long-term plans that comply with Affordable Care Act (ACA) requirements. This is problematic, because short-term plans with limited set benefits are not required to include coverage for services rheumatology patients with inflammatory arthritis and other conditions often depend on such as preventative care, rehabilitation services, prescription medication coverage and lab testing (which is needed for the diagnosis and subsequent monitoring of disease activity and medication toxicity).

“While we recognize extending the length of time people can carry short-term insurance may provide some individuals with more gap coverage than previously available, we are concerned patients may sign up for these short-term plans not realizing they don’t offer benefits they need to successfully manage their chronic conditions,” said David Daikh, MD, PhD, president of the ACR. “It is crucial that patients with chronic conditions are able to remain on their medications and that insurers do not limit access to required care.  Treatment decisions should be left to the provider.”

Additionally, the ACR worries that if prescription drug coverage is included, it will be minimal and may only cover one drug per class – which would greatly limit patients’ ability to access their needed biologic medications. If a patient with rheumatoid arthritis is unable to access critical biologic medications, they may face irreversible joint damage and disability.

The ACR recommends that insurance agencies be required to include a notice that these short-term plans may not cover all of the ACA’s essential health benefits, graphs and tables to compare the plans’ coverage to what the enrollee would receive under an ACA-compliant plan, and to provide specific guidance regarding the plan’s prescription and specialty drug coverage.

“The ACR is committed to ensuring that all rheumatic disease patients have access to affordable, quality healthcare, and we look forward to serving as a resource to CMS as it works to finalize this proposed rule,” said Dr. Daikh. 

Jocelyn Givens
404-633-3777, ext. 810


The American College of Rheumatology (ACR) is the nation’s leading advocacy organization for the rheumatology care community, representing more than 6,400 U.S. rheumatologists and rheumatology health professionals. As an ethically driven, professional membership organization committed to improving healthcare for Americans living with rheumatic diseases, the ACR advocates for high-quality, high-value policies and reforms that will ensure safe, effective, affordable and accessible rheumatology care.

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