Gail Hiller-Lee

If a company runs under the MLR, either the carrier or company payroll service need to be more responsible for the breakdown of the reimbursement. You can't have the employer figuring out who made a pre-tax payment and apply the credit after someone leaves. That would be taking a terminated employee's funds and distributing them to apply towards new hires - extremely unfair and should be illegal. The simplest way to return the premium is through employee accounts that allow the employee/terminated employee to use those funds similar to an FSA - for qualified expenses, including paying current contributions, Cobra payments, co-pays and deductibles, etc. If each individual that contributes has a plan linked to their contribution, a code could send that portion of money back into that account. THIS CAN WORK without having the employer hire someone to return the premium to current and terminated employees AND allow those people to use that money for pre-tax items, much like the money that went towards the premium. Lastly, please read my comments on Essential Benefits, Safe Harbor and The role of the agent and broker - all with valid points that I truly don't believe you are considering - especially the explanation of what we do every day for millions of insureds who could NEVER navigate their way through fighting claims, cleaning up insurance carrier injustices, etc. Thank you, Gail Hiller-Lee