Working to ensure that insurance carriers accept charitable payments on behalf of ESRD patients
In March 2014, the Centers for Medicare and Medicaid Services (CMS) released an Interim Final Rule (IFR), entitled the Patient Protection and Affordable Care Act: Third Party Payments of Qualified Health Plans Premiums. CMS stated that insurance carriers must accept charitable premium payments from state and federal organizations, tribal organizations, and the Ryan White HIV/AIDs organizations for the payment of premiums for QHPs. Since the IFR does not specifically state that insurance companies must accept charitable premium payments from not-for-profit organizations, many insurance carriers are refusing third party payments from AKF on behalf of patients with end-stage renal disease (ESRD) on dialysis.
Unfortunately, this practice has been extended to other types of insurance coverage beyond ACA Qualified Health Plans, including to Medigap. The plans stipulate that that coverage will be terminated if the individual accepts any direct or indirect contribution or reimbursement by or on behalf of any charitable organization, with the exception of the entities mandated by CMS as third party payers in their 2014 IFR.
AKF is fighting these discriminatory practices and we are advocating for the Department of Health and Human Services (HHS) to clarify their position on third-party payments, so insurance companies accept premium payments made on behalf of individuals with kidney disease.
Protecting ESRD patients from insurance carriers pushing them off private insurance
Individuals on dialysis are legally entitled to stay on their group health plan private insurance for 30 months prior to being required to move to Medicare. Many dialysis patients prefer to be on private insurance for as long as legally allowed, and it is their choice. Insurance carriers have employed tactics to encourage patients on dialysis to move to Medicare early by offering to pay for the patient’s Medicare Part B premium. Some insurance carriers have told beneficiaries that they must move to Medicare prior to the legal date. AKF is working with state regulators to address these practices.