April 23, 2018 Honorable Alex Azar Secretary Mr. David Kautter Department of Health and Human Acting Commissioner, Internal Revenue Services Service P.O. Box 8010 Department of the Treasury Baltimore, MD 21244-8010 1111 Constitution Avenue, NW Washington, DC 20224 Ms. Seema Verma Administrator, Centers for Medicare & Mr. Preston Rutledge Medicaid Services Assistant Secretary, Employee Benefits Department of Health and Human Security Administration Services Department of Labor P.O. Box 8010 200 Constitution Avenue, NW Baltimore, MD 21244-8010 Washington, DC 20210 RE: Comments on Limited-Duration Insurance Proposed Rule Dear Secretary Azar, Administrator Verma, Acting Commissioner Kautter, and Assistant Secretary Rutledge, [NAME OF ORGANIZATION] appreciates the opportunity to comment in response to the proposed rule on short-term limited-duration insurance. [About your organization.] [NAME OF ORGANIZATION] writes with strong objection to the proposed rule on term limited-duration insurance. The proposed rule rescinds restrictions on short-term plans, thereby allowing insurers to offer junk insurance policies to millions of consumers. These plans exclude coverage for critically important health care services; vary premium rates by gender, health status, and age; and put individuals and families at significant financial risk. In addition, expanding these types of plans will undermine the individual market by pulling healthy individuals away and leaving an older, sicker risk pool behind. Many individuals who rely on comprehensive coverage including women, older – adults, and people with chronic conditions would be left without affordable, – comprehensive options. Short-term policies offer junk insurance that fails to meet the needs of consumers. Short-term, limited-duration insurance is intended to provide temporary insurance during unexpected coverage gaps. This type of coverage is exempt from the definition of individual health insurance coverage under the Affordable Care Act (ACA) and, therefore, does not have to comply with the law’s core consumer protections. The proposed rule, therefore, promotes and will increase take up of skimpy, junk insurance coverage with minimal protections for consumers. Specifically, such coverage: Has high out of pocket costs, Limits the coverage people can receive each year and over their lifetime,
April 23, 2018 Honorable Alex Azar Secretary Department of Health and Human Services P.O. Box 8010 Baltimore, MD 21244-8010 Ms. Seema Verma Administrator, Centers for Medicare & Medicaid Services Department of Health and Human Services P.O. Box 8010 Baltimore, MD 21244-8010 Mr. David Kautter Acting Commissioner, Internal Revenue Service Department of the Treasury 1111 Constitution Avenue, NW Washington, DC 20224 Mr. Preston Rutledge Assistant Secretary, Employee Benefits Security Administration Department of Labor 200 Constitution Avenue, NW Washington, DC 20210 RE: Comments on Limited-Duration Insurance Proposed Rule Dear Secretary Azar, Administrator Verma, Acting Commissioner Kautter, and Assistant Secretary Rutledge, [NAME OF ORGANIZATION] appreciates the opportunity to comment in response to the proposed rule on short-term limited-duration insurance. [About your organization.] [NAME OF ORGANIZATION] writes with strong objection to the proposed rule on limited-duration insurance. The proposed rule rescinds restrictions on short-term plans, thereby allowing insurers to offer junk insurance policies to millions of consumers. These plans exclude coverage for critically important health care services; vary premium rates by gender, health status, and age; and put individuals and families at significant financial risk. In addition, expanding these types of plans will undermine the individual market by pulling healthy individuals away and leaving an older, sicker risk pool behind. Many individuals who rely on comprehensive coverage – including women, older adults, and people with chronic conditions – would be left without affordable, comprehensive options. Short-term policies offer junk insurance that fails to meet the needs of consumers. Short-term, limited-duration insurance is intended to provide temporary insurance during unexpected coverage gaps. This type of coverage is exempt from the definition of individual health insurance coverage under the Affordable Care Act (ACA) and, therefore, does not have to comply with the law’s core consumer protections. The proposed rule, therefore, promotes and will increase take up of skimpy, junk insurance coverage with minimal protections for consumers. Specifically, such coverage: Has high out of pocket costs, Limits the coverage people can receive each year and over their lifetime, term