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AAMC Submits Comments on Health Plans Proposed Rule

August 14, 2020

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CONTACTS
Mary Mullaney, Director, Hospital Payment Policies

The AAMC submitted comments on Aug. 12 in response to a proposed rule issued by the departments of Treasury, Labor, and Health and Human Services to allow grandfathered group health plans, including high-deductible health plans (HDHPs), to increase consumer cost sharing without losing their grandfathered status.

The AAMC said in its comments that it supports the availability of health insurance that is both affordable and comprehensive. However, as the proposed rule notes, grandfathered health plans are not required to meet the requirements set forth in the Affordable Care Act, which mandated that new health insurance plans provide coverage for certain services. The AAMC said it opposes allowing grandfathered group health plans that offer less comprehensive coverage to increase cost sharing for consumers and urged the departments not to finalize the proposed rule.

The proposed rule notes that there is the “potential increase in adverse health outcomes if a patient or beneficiary would forego treatment because the necessary services became unaffordable due to an increase in cost sharing.” Furthermore, the proposed rule offers no specific impact on the financial burden consumers will face as a result of the proposed increases in cost sharing stating that they “are unable to quantify all benefits, costs, and transfers of these proposed rules.” The AAMC urged the departments to fully evaluate and publicly report on whether increased cost sharing will lead to decreased utilization of necessary medical care.

The AAMC also noted that increasing cost sharing at a time when consumers are facing economic hardships as a result of the COVID-19 public health emergency will unnecessarily increase the emotional and financial stress they already feel and may cause many to delay or forgo needed care.

Finally, The AAMC letter pointed out that requiring consumers to assume increased cost sharing could further increase the number of under- and uninsured individuals, resulting in increased health care bad debt that would further exacerbate the financial strain hospitals and physicians already face.

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