On March 12, 2026, the Policy Center for Maternal Mental Health submitted a formal letter to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed 2027 Notice of Benefit and Payment Parameters.
We are concerned that high out-of-pocket costs and restrictive enrollment windows continue to act as disincentives for growing families. At a time when the U.S. is facing historically low birth rates, our health care policies should serve as an incentive to bear children, rather than a financial barrier.
The Policy Center is urging CMS to consider two critical changes: providing maternity and pediatric primary care at zero cost-share and classifying pregnancy itself as a qualifying life event for enrollment.
Below is our full letter outlining why these recommendations are a necessary step toward ensuring healthy pregnancies and economic stability for American families.
See the full letter below.
March 12, 2026
Dr. Mehmet Oz
Administrator
Centers for Medicare & Medicaid Services
200 Independence Avenue, SW
Washington, DC 20201
Submitted via www.regulations.gov
Re: Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2027; and Basic Health Program
Dear Administrator Oz:
The Policy Center works to close gaps in maternal mental health care. We appreciate the opportunity to provide comments on the 2026 Notice on Benefit and Payment Parameters released by the Centers for Medicare and Medicaid Services (CMS) which impact consumers who buy coverage through the Affordable Care Act exchange.
We acknowledge the CMS proposed 2027 rule (HHS Notice of Benefit and Payment Parameters) that aims to expand access to low-premium, high-deductible “catastrophic” Affordable Care Act (ACA) plans with terms of up to 10 years rather than just one year, increasing maximum out-of-pocket limits by 30% to over $15,600 for individuals, and expanding eligibility.
We urge you to consider two key changes.
- Covering Maternity and Pediatric Primary Care with No Cost Share
Given the current historically low U.S. birth rates and concerns about the need to boost the population to ensure economic growth, sustain entitlement programs like Social Security, and prevent labor shortages, ACA plans offered on the exchange should serve as an incentive to bear children, vs. a disincentive. Pregnancy, labor and delivery and postpartum care (“maternity care”), as well as pediatric primary care for births covered by the plan, should be provided at zero cost share. This provision should apply to all plans offered on the exchange, including catastrophic plans.
- Updating qualifying events for enrollment on exchange plans to include pregnancy, not just birth.
Currently, people can apply for coverage on the exchange when they meet the criteria for a qualifying event, including the birth of a child. We believe this is not sufficient, and pregnancy itself should also be classified as a qualifying event. This is critical to not only ensure healthy pregnancies and development in utero, but is also more important at this juncture, given the U.S. is facing historically low birthrates, and coverage should serve as an incentive to women and families to bear children.
Should you have any questions about these critical recommendations, please do not hesitate to contact me.
Sincerely,
Joy Burkhard, MBA
CEO
Policy Center for Maternal Mental Health
