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Health Care Groups Voice Concerns Over Short-Term Policies, Association Health Plans, HRA Rules

Comment Letter

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Published on Dec 14, 2017

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State Departments of Insurance received this letter, which AHIP signed along with the Blue Cross Blue Shield Association, American Cancer Society Cancer Action Network, American Heart Association, Families USA, and multiple other organizations. The letter voices concerns following the recent Executive Order on health care:

  • “Expanding and extending short-term, limited-duration health plans, increasing enrollment in Association Health Plans (AHPs), and relaxing rules for employer Health Reimbursement Arrangements (HRAs) all increase adverse selection in insurance markets that serve millions of individuals and employers. We are concerned that this could create or expand alternative, parallel markets for health coverage, which would lead to higher premiums for consumers, particularly those with pre-existing conditions.”
  • “We hope the federal agencies will avoid harming or undermining the individual market risk pool as they consider changes to the federal rules for short-term plans, AHPs, and HRAs. However, the Executive Order indicated an interest in allowing short-term plans to be sold for longer periods than the current limit of three months. Short-term plans are not comprehensive health insurance and are not required to meet the standards that are applied to individual market health plans.”
  • “Short-term plans don’t have to cover the essential health benefits, and may deny or charge more to people who have pre-existing medical conditions, exclude such conditions, and limit the amount of benefits they will pay out under the policies. If short-term plans are allowed to be sold as a long-term alternative to regular health insurance, they will attract healthier consumers away from the regular insurance risk pool and endanger people’s access to comprehensive coverage.”
  • “If the proposed federal rules are weakened for short-term plans, AHPs, or HRAs, we urge state insurance regulators to take action to protect consumers in your states.”