Health Connector clears path for deductible increases
Some health plans would be allowed to set higher deductibles for consumers and health care sharing arrangements established by religious organizations will face new reporting requirements under regulations approved by a state board on Thursday.
The Massachusetts Health Connector Authority board voted unanimously to update its minimum creditable coverage regulations to index deductibles, which are currently capped at $2,000 for an individual or $4,000 for a family. Connector staff has said the move is intended to balance both consumer protection and affordability.
The current deductible limits were set in 2007 and have not been updated to account for inflation, according to the Connector. The new regulations, which will take effect in January, will index the limits to a Department of Health and Human Services' premium adjustment percentage, a figure used to update other Affordable Care Act standards, and allow the Connector Board to adjust the indexing if necessary.
Feedback received during a public comment period was "generally supportive" of the change, said Marissa Woltmann, the Connector's director of policy. One comment -- submitted by Suzanne Curry of Health Care For All and Andrew Cohen of Health Law Advocates -- raised concerns about rising out-of-pocket consumer health care costs and suggested the Connector "analyze and share publicly any discernible impact of indexing deductibles."
Woltmann said the Connector intends to review and continue monitoring consumer costs. She said the authority plans to issue annual guidance to insurers on deductible setting, with the first round expected in March.
The minimum coverage standards govern plans that most Massachusetts residents are required to obtain to comply with the state's health insurance law. Adults who go three consecutive months without insurance that meets the minimum creditable coverage standards can be subject to tax penalties.
Thursday's vote also updated portions of the minimum creditable coverage regulations that deal with health arrangements established by religious organizations, such as health care sharing ministries.
In a health care sharing ministry, groups of people with a common religious affiliation share in the costs of members' health care. The ministries are exempt from Division of Insurance oversight.
"Specifically, our goal was to ensure that when consumers go to the market to find a way to pay for their health care needs, they are able to see their options clearly, with regulated health insurance on one end and health sharing arrangements on the other," Andrew Egan, the Connector's general counsel, said. "Our goal is to snap those distinct choices into focus by ensuring that health sharing arrangements are disincentivized to act in a way that would blur the line between them and traditional health insurance."
Aimed at protecting consumers from deceptive practices, the regulations establish that any such arrangement must be a not-for-profit and must provide "written disclosure that it is not insurance and does not guarantee payment of medical bills."
Membership in health care sharing ministries and other similar arrangements will continue to meet minimum creditable coverage standards, as long as the arrangements comply with certain criteria -- for instance, they cannot be for-profit companies, cannot engage in deceptive marketing, and must provide written disclosure that their service "is not insurance and does not guarantee payment of medical bills."
Health arrangements will be required to annually report information about their membership, operations, and finances to the Connector.
Board member Nancy Turnbull asked Egan how many people in Massachusetts are enrolled in health care sharing ministries.
Egan said the Connector does not now have reliable data on membership, but heard from one sharing ministry that has "a little over 600" members. The reporting requirements would include information on the number of people enrolled, which Turnbull said would provide helpful context.
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