American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

ACS Comments on Interstate Insurance Sales

The American College of Surgeons (ACS) submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) May 6 in response to the agency’s request for information (RFI) about ways to facilitate the purchase of health insurance across state lines. In this RFI, CMS specifically sought input on how to operationalize interstate insurance sales, which the agency asserts would increase competition among payors and provide consumers with more affordable health plan options.

The ACS opposed CMS's efforts to promote the sale of insurance across state lines and indicated that such a business model could impede meaningful access to comprehensive medical care, shift out-of-pocket expenses to patients, create narrow networks of specialty providers, and unfairly reduce reimbursement rates for physicians. The College expressed concern that, without proper regulatory oversight, payors may design “bare bones” plans with limited benefits in order to reduce premiums and attract out-of-state consumers. Consequently, individuals who purchase these plans could unknowingly be left without coverage for the full spectrum of items, services, and providers needed to best manage their health care conditions. The ACS urged CMS to ensure that, before the agency modifies any policy change that could dramatically change insurance markets across the country, strict enforcement mechanisms for care access and quality are in place to protect patients’ ability to receive necessary treatment.

For more information about the RFI and College’s comments, contact Lauren Foe, Senior Regulatory Associate in the ACS Division of Advocacy and Health Policy, at