NY - Bernard A. Hiller, Inc.

1: THE IDEA OF THE METAL SYSTEM IS UNDERSTANDABLE BUT THE COST SHARING MAKES LITTLE SENSE. IF WE ARE TAKING THE MOST EFFECTIVE AND LARGEST OF PLANS PER STATE AND MIMICKING THOSE BENEFITS, ALONG WITH THE EHB'S - TAKE THE SAME PLAN AND ITS BENEFITS AND INCREASE COST SHARING WITH GREATER OUT OF POCKETS TO CHANGE THE OUT OF POCKET PERCENTAGES EQUALING THE METAL PERCENTAGES. EX: PLATINUM WOULD HAVE LOWER OUT OF POCKETS/HIGHER PREMIUM VS BRONZE WITH HIGHER OUT OF POCKET AND LOWER PREMIUM. FOR ACTUAL CLAIMS, WORK IT SIMILARLY TO THE ARRA SUBSIDY - HAVE THESE CLAIMS SUBMITTED TO AN AGENCY CENTRAL THAT TRACKS SUBSIDIES AND HAVE THE AGENCY PAY THAT PORTION THAT THE ENROLLEE IS ENTITLED TO. ANYONE ENTITLED TO A SUBSIDY WOULD HAVE THE COST PARTIALLY PAID AND THE PERCENTAGE OF ENTITLEMENT FOR THE ACTUAL CLAIMS PAID TO THE PROVIDER. 2: IF THE INDIV AND SMALL GROUP MARKET ARE COMBINED BUT YOU WILL IMPOSE MINIMUM PARTICIPATION REQUIREMENTS ON THE SHOP PLANS, YOU ARE MIXING TWO SPECIFICALLY DIFFERENT QUALIFICATIONS TO OBTAIN INSURANCE AND THE RISK SEEMS TO COVER A DIFFERENT CRITERIA. IN THE SHOP PLAN YOU ARE STATING THAT THERE MUST BE A PERCENTAGE OF PARTICIPATION BECAUSE OF THE RISK SPREAD AMONG A LARGER GROUP - SOME MAY GO TO THE EXCHANGE DIRECTLY AND SOME MAY STAY IN THE SMALL GROUP. EITHER WAY, THEY ARE ALL GOING TO HAVE INSURANCE THROUGH THE EXCHANGE. SO WHY IMPOSE ANY RESTRICTIONS ON PARTICIPATION? YOU ARE DISCOURAGING SMALL BUSINESSES FROM HOLDING EMPLOYEES THAT WANT INSURANCE THROUGH THEIR EMPLOYER FROM BEING COVERED IN THAT MANNER IF A SMALL PERCENTAGE GO DIRECTLY TO THE EXCHANGE. THE IDEA OF BEING ABOUT TO KEEP WHAT YOU HAVE WILL NOT BE TRUE AT THAT POINT SINCE YOU ARE POTENTIALLY THE DRIVER OF THE DEMISE OF THE GROUP PLAN. IF 60% WANT THEIR GROUP PLAN AND THE HHS SAYS THAT THAT ISN'T ENOUGH OF A PARTICIPATION PERCENTAGE, YOU ARE TAKING AN EMPLOYER BENEFIT AWAY FROM 60% OF AN ACTIVE COMPANY THAT WANTS TO PROVIDE A WORKING BENEFIT TO ITS EMPLOYEES