Just before the Thanksgiving holiday, Health and Human Services (HHS) released the long awaited Certification of Comparability of Pediatric Coverage Offered by Qualified Health Plans. You might remember the Affordable Care Act (ACA) requires the Secretary to review the benefits and cost sharing in Marketplace qualified health plans (QHPs) and certify those plans that offer benefits and cost sharing that are at least comparable to their states’ Children’s Health Insurance Program (CHIP) plans. In short, the Secretary did not certify any QHPs at this time. This is a strong signal that continued advocacy is necessary to both re-fund CHIP and improve Marketplace plans for children.

What’s in the Report?

Health and Human Services (HHS) reviewed the second lowest cost silver plan (SLCSP) in states, comparing it to the state’s CHIP coverage. In table form, they list how 36 states perform on both actuarial value (AV) and out-of-pocket (OOP) costs for families (premium + cost sharing). The results are staggering. For example, in Virginia the OOP for CHIP families is $21 whereas for a QHP it’s $754, on average. In Montana, the OOP moves from $5 to $1,111, on average, and in Maine, from $115 to $824, on average, for CHIP and QHPs, respectively. Average OOP spending in the SLCSP was higher than OOP spending in CHIP in every state on a per child basis under CHIP and under the SLCSP with financial assistance. These are real dollars for families and if the necessity to transition from CHIP to the Marketplace were to arise at this stage, it could prompt many parents to compromise their own health and forgo coverage in an effort to keep their children covered.

Beyond cost sharing, there is the issue of benefits. HHS found that child-specific benefits were lacking in QHPs at this time. Most notably—dental, vision and habilitation services are deficient. After the last round of EHB selection, these benefits have slightly improved, but still leave gaps in coverage. Children with special health care needs rely on these benefits to support their daily living and long-term health outcomes.

The Key Takeaways?

First, this HHS report clearly signals that the Marketplace is not ready for kids. Second, there is real work to be done to ensure that Marketplace plans are child-friendly—both in terms of cost sharing and benefits. And finally, continued CHIP funding is necessary to protect families while we work to ensure Marketplace plans are robust enough to serve all children.

The comparability report comes at a good time. Funding for CHIP runs out in September 2017. Right now, many advocates are building their 2016 work plans and are prioritizing what is ripe and what is necessary to keep kids healthy. CHIP is a 2016 priority. Type it into your work plan, and let’s roll up our sleeves and ensure that all children will continue to have access to needed coverage. The Marketplaces are not ready for our youngest and most vulnerable consumers, and now the HHS study has made that abundantly clear.