Today’s Managing Health Care Costs Number is $100
The Wall
Street Journal reported Monday that some employers are considering or
adopting “bare bones health plans” to minimize their costs under the Affordable
Care Act.
What’s a bare bones health plan?
One that pays for preventive care, but limits
hospitalization coverage to, let’s say, $100 per day. (In Boston, that is unlikely to purchase an
hour at a hospital –never mind an entire day!) Some plans don’t provide
coverage for x-rays, surgery, or prenatal care!
How could this be legal under the Affordable Care Act, which
is supposed to standardize health plans to allow for easy comparison shopping
(as noted yesterday this helped pressure two Oregon plans to petition to lower
their premiums)?
The ACA strictly regulates health plans that are fully
insured –although even here the standard is the average percentage paid out of
pocket (i.e. a “silver” plan covers on average 80% of cost, leaving patients on
the hook for 20% of cost on average). The act is much more “hands off” for
self-insured plans where employers themselves pay the ultimate costs. Self-insured plans cover 130 million of the
total 160 million Americans with private coverage. The
ACA mandates coverage of preventive care and prohibits lifetime and annual
limits – but isn’t prescriptive about what is credible coverage. The Obama administration has left this to the
states.
Some states are pursuing
vigorous regulation to prevent sales of inherently defective insurance
policies, which would be highly likely to leave those with serious illness in
financial ruin. Other states intend to
“let the market decide.” The federal
government, however, is much less strict.
The federally-administered exchanges will not require insurers to have
consistent and comparable benefit plans, and will it hold competitive bidding –
but rather simply will allow insurers who meet a minimum threshold to be listed
in the exchange. That’s easy to administer – but means critical consumer
protections will not be in place. The
federal government will operate exchanges in 34 states.
The ACA won’t penalize companies the across-the-board $2000
penalty for not offering insurance at all if they offer one of these defective
plans. However, employers could still
be on the hook for a $3000 per employee penalty for employees who opt out and accept
federal subsidies for the exchange products.
The employers would gladly pay this penalty, because those
opting out would be especially expensive – and the penalty would be cheaper
than paying for their legitimate medical costs. Worse still, this will lead to
adverse selection making health plans on the exchanges very expensive.
Bare bones health plans
-
Provide inadequate health insurance, especially
for low wage workers
-
Allow employers to shift adverse risk to the
plans sold on the exchange
-
Threaten to cause exchange rates to be
unsustainably high due to this adverse selection, which could threaten the
viability of the exchanges.
Just like the “mini-med” plans before them, which capped
total payments at a few thousand dollars, these bare bones health plans give
the illusion of coverage – which is whisked away just when the member really
needs it. Regulators should take notice, and create a
regulatory structure that does not provide advantages to employers who design
such defective plans.