April 12, 2012

Ms. Patty Fontneau

Executive Director

Colorado Health Benefit Exchange

303 East 17th Avenue, Suite 930

Denver, CO 80203

RE: COHBE Advisory Groups

Dear Director Fontneau,

One Colorado is pleased to have the opportunity to comment on the Colorado Health Benefit Exchange’s (COHBE) intent to establish advisory groups, as was discussed at the COHBE Board meeting on April 9, and in the April 3 COHBE “Recommendations for Advisory Groups” memorandum. We support an advisory group structure that includes opportunities for robust stakeholder participation, meaningful representation of the diversity of Colorado’s population, and discussion of policies that will improve access to comprehensive and equitable coverage through the exchange. In particular, we encourage COHBE to establish advisory groups in a manner that provides adequate representation of lesbian, gay, bisexual, and transgender (LGBT) Coloradans.

Consumer Representation on COHBE Advisory Groups

We believe that advisory groups provide a key opportunity for stakeholder involvement to inform and guide the COHBE Board in making policy decisions that address the needs of all Coloradans and that will support the success and longevity of the exchange. We urge COHBE to establish a transparent process for selecting representatives to serve on the advisory groups. This process should also address the need for participation by diverse stakeholders, including representative consumer advocates and advocates for the various vulnerable and underrepresented populations that the exchange will serve, such as the LGBT population.

Issues Addressed by the Proposed Advisory Groups

  • Health Plan Advisory Group. The April 3 COHBE staff memorandum states that this group will assist in defining the essential health benefits for Colorado. Recommendations and decisions pertaining to the essential health benefits will have a profound impact on access for all Coloradans to affordable, comprehensive coverage for medically necessary care. To ensure that the health needs of plan enrollees are adequately represented in this crucial decision-making process, the composition of this group must be expanded beyond representatives from health plans, the DOI, exchange, and the exchange vendor(s). Stakeholder participation in line with U.S Department of Health and Human Services preliminary guidance on the essential health benefits requires that consumer stakeholders and members of the public have meaningful participation in the process. To this end, any advisory group addressing the essential health benefits must include participation of diverse individuals that will be served by the exchange, including individuals representing populations affected by health disparities and representatives from vulnerable and underserved communities, such as the LGBT community.
  • Retail Channel Advisory Group. The description of this advisory group offered by the April 3 COHBE staff memorandum is unclear regarding the degree to which this advisory group will assist in defining the requirements for consumer-access tools and navigator entities. We urge the COHBE Board to clarify the role this advisory group will play in providing input pertaining to consumer accessibility and information access regarding plans offered through the exchange, as well as to what degree the recommendations provided by this advisory group will overlap with those provided by the Individual Experience Advisory Group.
  • Individual Experience Advisory Group. The role of this group in addressing access, services, and support for the individual exchange will be essential to ensuring inclusivity and equity for groups of consumers who are disproportionately uninsured, including the LGBT community. To this end, we recommend that the “cultural perspectives” represented in the composition of this advisory group include the perspective of individuals and advocates knowledgeable about health access and outcome disparities experienced by LGBT Coloradans.

We thank the COHBE for the opportunity to comment on the advisory group establishment process. If you have questions regarding these comments, or other opportunities for ensuring equity for LGBT Coloradans in the exchange, please do not hesitate to contact me at or 720-413-5229. Thank you for your consideration.

Sincerely,

Brad Clark

Executive Director

DENVER
1245 E. Colfax Ave. #204
Denver, CO 80218
303.396.6170 / FORT COLLINS
212 S. Mason St.
Fort Collins, CO 80524
970.221.3247 / COLORADO SPRINGS
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Colorado Springs, CO 80909
719.434.8564 / GRAND JUNCTION
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Grand Junction, CO 81501
214.298.4446