There has to be parity between Exchange and non-Exchange product. Therefore commissions, minimum participation requirements, etc have to be equal between all products.
Additionally, merging small group and individual markets creates an unknown and unquantifiable situation. By definition, the Exchange is adding uninsured to the marketplace who are individuals with no history. Merging the pools prior to having credible experience for these people could cause rates in subsequent years to increase dramatically if carriers make incorrect assumptions about the claims experience. It's best to hold off on this until 2017 when more information is available.
NY
This is comment on Proposed Rule
Patient Protection and Affordable Care Act: Health Insurance Market Rules; Rate Review
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