The California Medical Association (CMA) has filed formal comments objecting to a proposed federal rule that would change the way consumers are billed for health insurance exchange plans that cover abortion services.

The proposed Exchange Program Integrity rule would require plans to send two separate monthly bills to each policyholder: one bill for the non-Hyde abortion coverage (at least $1 per member per month) and one bill for all other services. This would mean consumers would have to pay their monthly premium in two separate transactions.

CMA believes the proposal threatens to disrupt coverage for consumers nationwide, with particularly harmful impacts for California. California law requires most health plans to cover abortion services, and 1.395 million people were enrolled in 2018 coverage in a Covered California qualified health plan.

Two separate bills will cause confusion and member abrasion, particularly if the additional hassle is for a single dollar. Enrollees will be confused by an “other premium” bill for the majority of their coverage premium and a separate $1 non-Hyde premium and may, either out of confusion, or lack of awareness of the consequences, not pay the $1—putting them at risk of having their policy cancelled.

The proposed rule would also create additional costs and administrative burdens for health plans, which could decrease plans’ willingness to offer comprehensive women’s health coverage in the exchanges.