Officials at the National Association of Insurance Commissioners say details about association and out-of-state trust health plan rate review programs are hard to get.
The officials have sent the comments to the U.S. Department of Health and Human Services (HHS) in response to a section in a health insurance rate review regulation published in May.
HHS developed the regulation to implement the Patient Protection and Affordable Care Act of 2010 (PPACA).
In the regulation, HHS officials asked for comments on how associations should be treated in health rate reviews.
Some business groups and insurance producer groups have suggested in recent years that expanding access to national or multi-state association health plans could help hold down coverage costs.
But NAIC officials report that, when they set about answering the HHS questions about association and out-of-state trust plans, their sources of information were relatively meager.
NAIC President Susan Voss and the other NAIC officers and committee chairs who signed the letter say they relied on their own experience, interviews with representatives from 6 health insurers that sell coverage through associations and out-of-state trusts, and responses from 31 states to a survey conducted by Washington state insurance regulators in November 2010.
“HHS may want to collect additional information directly from the organizations that sell this coverage and from the insured persons who have purchased the coverage before making a final determination of how the rate review requirements in the Affordable Care Act apply to this type of medical coverage,” officials say.
Only about 10 states could come up with reasonably firm estimates of the percentage of residents who have individual, family or group association coverage. Answers ranged from 1% to 66% for small group coverage and 1% to 72% for individual coverage. The states that used more formal methods to come up with association plan penetration figures reported much higher percentages than the other states.