A proposal to expand the definition of short-term, limited-duration insurance stands to hurt enrollees, destabilize the insurance market and make health insurance more expensive for women and older, sicker individuals, the AAFP recently warned HHS in a letter.
But the Academy suggested an important regulatory change that would improve the nation's health care system: eliminating cost-sharing for standard primary care benefits in high-deductible health plans (HDHPs).
The bulk of the April 18 letter(4 page PDF) to HHS Secretary Alex Azar, signed by Board Chair John Meigs, M.D., of Centreville, Ala., focused on a proposed rule(www.gpo.gov) published in the Feb. 21 Federal Register. The rule would allow short-term, limited-duration insurance to be purchased for any period of less than a year rather than the current limit of less than three months.
"The AAFP believes short-term, limited-duration plans are meant to be a bridge, not a substitute for long-term meaningful coverage," the AAFP wrote.
The proposal would encourage sales of low-value plans exempt from consumer protections such as the requirement to cover pre-existing conditions or essential health benefits -- and with benefit caps.
"We are troubled by how the proposed rule would further destabilize the individual market by drawing young, healthy people away from meaningful, comprehensive coverage," the Academy stated. "Allowing younger and healthier individuals to gamble with low-quality insurance will raise the premiums of those with Patient Protection and Affordable Care Act (ACA)-compliant plans, which would have the detrimental effect of putting better coverage beyond the reach of millions of the sickest Americans."
All private commercial health plans should adhere to the ACA's requirement to cover essential health benefits to prevent discrimination based on health status, age or gender. The proposed rule would drive up costs for women, as well as for older and sicker Americans, by allowing insurers to exclude certain health services.
"In doing so, insurers could potentially make plans more expensive for people with long-term chronic conditions or with sudden medical emergencies," the letter stated. "Inadequate benefits could leave this population with too little coverage to meet their health care needs."
The AAFP pointed out that the proposed rule would require short-term, limited-duration plans to warn consumers about drawbacks in 14-point capital letters.
"While we appreciate that HHS acknowledges that a warning is needed, we also note that its very existence argues against the creation or promotion of short-term, limited-duration insurance plans," the AAFP wrote.
Instead, the administration should implement the AAFP's proposal for a standard primary care benefit(6 page PDF) for individuals and families with HDHPs. This benefit would allow patients to access following services with no cost-sharing:
- evaluation and management codes 99201-99215,
- prevention and wellness codes 99381-99397,
- chronic care management codes and
- transition care management codes.
Unlike the proposal to expand low-value health plans, the AAFP's initiative is projected to save money for individuals, families and employers.
"The establishment of a standard primary care benefit would guarantee connectivity to the health care system for individuals with HDHPs and serve as a guardrail against disease progression that leads to more costly care," the AAFP wrote.
Related AAFP News Coverage
AAFP Warns Against Expanding Association Health Plans
Labor Department Proposal Would Sidestep Essential Health Benefits Rule