On June 15, 2026, The Centers for Medicare and Medicaid Services (CMS) released an RFI, asking for input into potential changes to how the federal government implements the Affordable Care Act’s (ACA’s) Essential Health Benefits (EHB) requirements. The ACA requires plans in the individual and small group markets to cover a set of ten EHB categories and gives a great deal of discretion to the Secretary of the Department of Health and Human Services (HHS) to determine how to define the specific services within these categories. HHS has chosen to implement the EHB requirement through a benchmark process, where states choose from an “EHB benchmark plan” from a set of existing plans. All plans subject to EHB in that state must provide coverage that is “substantially equal” to the coverage offered across the ten EHB categories in the state-selected EHB benchmark plan. CMS is now asking for feedback and input on whether it should change this process.
In a considerations document, CHIR Faculty Amy Killelea analyzes the RFI and outlines EHB considerations for people with insulin-requiring diabetes broken out by topic. Through this comment period, diabetes advocacy organizations and providers can provide input to help ensure equitable and affordable access to clinically appropriate care and treatment.
