Health insurers like the Blue Cross Blue Shield Association and America's Health Insurance Plans questioned how a rule on health reimbursement arrangements would affect health insurance markets, according to AJMC.
Here are four takeaways:
1. The proposed rule, released in October 2018, aims to allow small- and medium-sized companies that don't currently provide employer-based insurance coverage to use health reimbursement arrangements. HRAs allow employers to put tax-free dollars in workers' accounts to cover future medical expenses. Under the proposed policy, companies may use HRAs to reimburse employee premiums on the individual ACA market up to $1,800.
2. BCBSA and AHIP questioned how allowing HRAs to be used to buy short-term health plans would affect risk pools. They cautioned the change could allow healthier employees to combine HRAs with short-term plans, which could negatively affect the industry by creating unbalanced risk pools.
3. In a letter to IRS Commissioner Charles P. Rettig obtained by AJMC, AHIP said: "Permitting HRAs to be integrated with STLDI [short-term limited duration insurance] would open the door to employers replacing coverage that is prohibited from discriminating based on pre-existing conditions with coverage that may charge more for pre-existing conditions or deny enrollment outright. It could also lead to significant increases in individual market insurance premiums in states where a significant number of employees are offered Integrated HRAs by their employer."
4. The BCBSA said in its letter that the "agencies should carefully monitor enrollment in the new HRAs, including tracking this by firm size, and the impact that ICHRA enrollees have on the affordability of individual market coverage. If ICHRAs are having a material negative impact on individual market pricing, modifications should be made to the ICHRA requirements."
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