On October 3, 2022, Aimed Alliance submitted a comment to the Department of Health and Human Services (HHS) on its’ proposed Section 1557 Rule. Section 1557 of the Patient Protection and Affordable Care (ACA) prohibits discrimination on the basis of race, color, national origin, age, disability or sex (including pregnancy, sexual orientation, gender identity, and sex characteristics) in covered programs and activities. Our letter to HHS supported recognizing that Section 1557 includes discrimination in benefit design and excessive benefit utilization policies; and reiterated our long-standing position against the use of discriminatory quality adjusted life year (QALY) value assessments. Lastly, our letter encouraged HHS to consider how third-party programs that partner with health plans to manage their specialty benefits could be liable under Section 1557 for convincing health plans to adopt discriminatory plan designs. Read our letter here. HHS’s proposed Rule can be found here.