Kilpatrick Townsend

DOL RFI for Preventive Care

As noted last week, the DOL announced on its webpage that it would publish an RFI regarding possible value-based plan designs in light of the preventive care requirements.  (A nongrandfathered plan is required to provide preventive care, as defined by the Agencies, at 100% with no deductible and no coinsurance for in-network claims.)  Based on the preventive care requirements, it is hard to see how plans could offer incentives in the context of preventive care (unless the existing regulations are revised).  However, the Agencies remain interested in ideas on how this could be accomplished.  Specifically, the RFI solicits information on specific examples and best practices of value based designs for recommended preventive services, as well as data used to support and inform benefit design, measurement, and evaluation in the context of recommended preventive services.  The text of the RFI is located here: