Comments Submitted to U.S. Health and Human Services on Rate Review

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Stacey Pogue /(512) 320-0222 x 117

July 14, 2011

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CPPP submitted comments to the U.S. Department of Health and Human Services (HHS) urging HHS to protect health insurance consumers by broadly applying rate review and disclosure provisions from the Affordable Care Act. Rate review is an important tool for expanding health insurance coverage by controlling costs. HHS requested comments on whether health insurance sold through “association health plans” should be treated like other insurance sold to individuals and small businesses, and subject to new rate review protections.

Nationwide, millions of people buy insurance through associations, a way for self-employed people and other individuals to access insurance. Association plans sold to individuals in Texas are not treated in the same manner as other insurance sold to individuals—rates for this coverage are not filed or reviewed.

CPPP believes that ALL Texas consumers deserve rate review protections, whether they are in a traditional health plan or one sold through an association. Our comments urged HHS to explicitly ensure that association plans sold to individuals are regulated as part of the individual market and small group association plans are regulated as part of the small group market, so that loopholes in regulations will not prevent Texas consumers from new protections meant to help bring down costs for consumers and increase transparency.