An actuarial consultant says well-meaning regulators who change the rules that govern the group health plan stop-loss market could promote the behavior they are trying to prevent.
William Lane, an acuary who is a principal at Heartland Actuarial Consulting L.L.C., Omaha, Neb., explains his concerns in an analysis sent to the National Association of Insurance Commissioners (NAIC), Kansas City, Mo.
The NAIC’s ERISA Working Group has included the analysis in a packet of materials posted in preparation for a working group session at the NAIC’s summer meeting, which is set to take place Aug. 11 in Atlanta.
The session agenda calls for the working group to discuss the idea of recommending guideline amendments that would increase the amount of health claim risk that small employers must keep when they use stop-loss insurance to limit the risk involved with offering a self-insured group health plan.
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Lane notes that he does not want his analysis forwarded in an incomplete form. The analysis starts on page 9 in the NAIC packet.
Some health policy observers want state or federal regulators to limit small employers’ access to stop-loss insurance, to reduce the likelihood that the small employers will use a combination of self-insurance and stop-loss insurance to avoid complying with the new health plan rules contained in the Patient Protection and Affordable Care Act of 2010 (PPACA), such as rules describing the “essential health benefits” that an insured plan must offer and rate review rules that apply only to insured plans.
Regulators suggested minimum stop-loss deductible levels in the Stop-Loss Insurance Model Act of 1995.