ACS CAN Comments on Interstate Sale of Insurance
ACS CAN Comments on AHP proposed rule
On March 6, 2018, ACS CAN filed comments on the proposed rule implementing changes to the Employee Retiree Income Security Act’s (ERISA’s) definition of “employer” for purposes of determining when employers may join together to form an Association Health Plan (AHP). We noted our previous opposition to federal initiatives to encourage the growth of AHPs because these plans promote the growth of products that do not provide comprehensive coverage, could damage the non-AHP individual and small group markets, and inadequately address issues of plan solvency and regulatory oversight, especially in light of the long record of AHP fraud and solvency problems. As discussed in more detail in our comment letter below, we outlined several concerns we with have with the proposed rule in its current form. We believe this proposed rule should not be finalized until the needs of the patient community have been met.