Comments on Proposed Health Reimbursement Arrangement Regulations

In general, ACAP supports the Departments’ proposal to permit Integrated HRAs be used for ACA-compliant coverage, with the caveat that adequate protective guardrails must remain intact in order to prevent employer-dumping of costly enrollees into the individual market. The ultimate impact of the rule will depend on the uptake by employers and health status of employees that shift into the individual market (see next section). Additionally, ACAP objects to permitting either Integrated HRAs or Excepted Benefit HRAs to be used for the purchase of STLDI coverage.

Regulatory Analysis
Health Reimbursement Arrangements (HRAs) have the potential to be a significant market driver, changing the overall form and structure of the individual market, depending on how they are implemented. The final rule could either be a major market destabilizer in which the individual market becomes nothing more than a dumping ground for high-risk employees, or it could lead to significantly improved risk and millions of new lives purchasing coverage in the individual market, thereby lowering costs for all consumers. Given the significance of this rule and any potential changes, we have asked Wakely Consulting Group to evaluate the proposed rule’s impact on the individual market—including an assessment of scenarios that could help or harm in the individual market risk pool. The complete paper is attached in full (please see Appendix A) as part of our comments submitted for the record.

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