The National Association of Insurance Commissioners refers directly to various types of limited-benefit health insurance products in its comments on the new federal health insurance rate review law.
The Accident and Health Working Group at the NAIC, Kansas City, Mo., took charge of developing an NAIC response to a request for information about state rate review programs and NAIC rate review rules and views issued by federal agencies in April.
The agencies are responsible for implementing rate review provisions in the Affordable Care Act, the legislative package that includes the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act.
The provisions require federal agencies to work with states to impose tighter limits on health insurance rate increases.
“PPACA addresses only health insurance that covers medical services provided by physicians, hospitals and other medical providers,” the NAIC notes in general comments on rate review programs.
“The PPACA requires removal of limitations on annual benefits, and eventually coverage of ‘essential benefits,’” the NAIC writes. “The PPACA does not specifically prohibit “mini-medical” insurance that covers medical services in a limited way, but the issuers of these plans may withdraw from offering these plans, because they are specifically designed to be low-cost limited coverage plans.”
Similarly, issuers of student “blanket” comprehensive medical coverage might drop out of the market, “because students will either be covered on their parents’ plans or will be required to purchase individual comprehensive coverage,” the NAIC writes.