In its 2016 Notice of Benefit and Payment Parameters, the Centers for Medicare and Medicaid Services (CMS) included new language translation requirements designed to assure that ESL populations can access and navigate exchange plans. The policy, which stipulated that certain plan materials must be translated into the top 15 languages in the state in which they operate, prompted concerns from industry including the National Association of Dental Plans (NADP), which argued compliance with this new rule would be costly and not in line with requirements in other markets.
In a recent memo, CMS amended that language to allow exchanges that operate in multiple states to use the top 15 languages across all service areas. Mike Adelberg, senior director for FaegreBD Consulting, told Inside Health Policy that CMS was wise to adjust the new rule.
“Applying the Top 15 standard to every state that a national health plan or dental serves was going to be expensive,” Adelberg said. “Given the lack of diversity in many states, the [return on investment] for this requirement was just too low. The agency was right to recalibrate to a single aggregated Top-15 list per carrier.”
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