ARA submitted comments to the Employee Benefits Security Administration and Department of Labor on March 5, 2018 regarding a Notice of Proposed Rulemaking on Association Health Plans (AHPs). For many years ARA has supported allowing associations to provide health insurance to members through AHPs because member organization, such as ARA, are uniquely suited to aggregate their workforces to provide cost effective, competitive and flexible health care options for thousands of employees.
In its comments, ARA noted that the Association firmly agrees with comments submitted by the American Society of Association Executives (ASAE) which include that “…the economies of scale that an AHP could produce would allow the association to offer more comprehensive coverage than members could afford on their own, implement realistic risk pooling, and minimize compliance cost.”
Specific recommendations to the proposed rule included:
– State health insurance regulations and laws should be distinctly preempted to allow for businesses that cross state lines.
– AHPs need to affiliate with an association that has a membership nexus to avoid fraudulent activities by newly formed AHPs.
– Employers or “working owners”, not just employees, of association members should be allowed to join an AHP by further clarifying their status and qualifications.
ARA applauds the U.S. Department of Labor’s efforts at perfecting and clarifying regulations that will result in an improved competitive health care landscape for businesses to self-insure with fewer regulatory burdens.