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Substitution of Essential Health Benefits

The Maryland Insurance Commissioner will hold a public hearing to receive testimony on the creation and enforcement of the substitution rules for benefit design under the State’s Essential Health Benefits(EHB) Benchmark Plan at 9 a.m. on Nov. 16, 2012. The public hearing will take place at the Maryland Insurance Administration, 200 St. Paul Place, Baltimore, in the Francis Scott Key Room on the 22nd floor.
Interested parties are invited to attend the hearing and testify. Questions and testimony should address one or more of the following topics:

For benefits other than in vitro fertilization:

Please provide arguments for and against instituting a "no substitutions" policy regarding essential health benefits for the 2014 plan year. This would be re-evaluated at a later date for 2015. This restriction would not include creative plan designs that provide additional benefits (for example through step therapy) or changes in provider networks.

For the in vitro fertilization benefit:

The Health Care Reform Coordinating Council mandated that there be "liberal substitution of the IVF benefit." Please provide comment on the following four substitution options:

  • Substitution of the IVF benefit for other benefits across EHB benefit categories.
  • Substitution of the IVF benefit for other benefits only within the Ambulatory Care category.
  • Substitution of the IVF benefit for other benefits only within the Maternity category.
  • Substitution only of quantitative aspects of the IVF benefit (for example, attempts per live birth) for other benefits.

Written comments and any questions regarding this matter should be directed to Megan Mason, Special Assistant to the Commissioner for Health Care Reform, and may be transmitted by mail to 200 St. Paul Place, Suite 2700, Baltimore, Maryland 21202, by phone to 410-468-2021, by fax to 410-468-2020, or by e-mail to