ACAP Comment Letters on Continued CSR Funding

On August 10, 2017, ACAP submitted two comment letters to both the Administration and to Congress regarding the importance of continued funding for CSRs.

On behalf of enrollees that receive coverage from Qualified Health Plans (QHPs), the providers
who serve them, and the insurance organizations that provide that coverage, we urge you to
continue funding for consumers’ cost-sharing reductions (CSRs) in the Marketplace.

Without guaranteed CSR funding:
• Issuers will drop coverage. Many issuers have already determined that they are unable to
participate in the Marketplace for 2018; without a commitment to continued CSR funding
other issuers will also stop offering Marketplace coverage—potentially even in 2017 if
funding is eliminated mid-year.

• Premiums will increase. Without CSR funding, there will be additional double-digit
premium increases for 2018 from issuers that do continue offering Marketplace coverage.

• Consumers will have limited options for purchasing insurance. Consumers who purchase
insurance on the Marketplace, will have fewer coverage choices, and in some areas none.
Those coverage choices that are available will be unaffordable to low-income consumers in

• Uncompensated care will increase, placing increased burden on providers. Individuals
unable to purchase insurance due to lack of coverage options and increased premiums will
become uninsured. Local providers will face the increased burden of providing
uncompensated care to these individuals.

• Federal spending will increase as a result of defunding CSR. Taxpayers will be forced to
pay billions of extra dollars on advanced premium tax credits to compensate for the increased
premiums resulting from a loss of CSR funding. Many states have already asked for a second
set of proposed rates from issuers, in the case that CSR funding does not continue. These
increased rates will translate to increased Advance Premium Tax Credits (APTC), which will
ultimately cost the Federal government more than simply paying the CSRs would have.


View the full comment letter to the Administration »

View the full comment letter to Congress »