Public Comment Letter: Protecting ERISA to Enable Affordable, Quality Coverage

US Capitol Building

On March 15, 2024, CareFirst BlueCross BlueShield (CareFirst) submitted comments in response to a Request for Information from the House Committee on Education and the Workforce on the Employee Retirement Income Security Act of 1974 (ERISA).

CareFirst emphasized the importance of ERISA in enabling employers to provide affordable, customized health coverage to employees in multiple states, and recommended Congress clarify that ERISA preempts state laws that interfere with it.

We highlighted that a growing patchwork of state laws imposing requirements on employers directly contradicts the original intent of ERISA. We also stressed the need to align cybersecurity requirements, including those related to incident and breach notifications, across states. Additionally, we emphasized the importance of allowing employers to utilize innovative approaches for covering and ensuring access to high-cost specialty drugs.

Read the full comment letter from CareFirst here.