Comment: NAIC Model Small Group “Bona Fide Associations”

The NAIC has circulated a revised Small Group Market Health Insurance Coverage Model Act with provisions narrowly defining “bona fide associations.” The NAIC should avoid additional, unnecessary deviation from federal standards. The proposed definition serves no useful purpose other than to insult those who did not go to college. The proposed NAIC draft defines “bona…

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HHS Preempts State regulation of Association Plan Rates

“Coverage that would be regulated as small group market coverage … if it were not sold through an association is subject to rate review as small group market coverage.” With that single sentence, the U.S. Department of Health and Human Services amended its recently adopted health plan rate regulations and preempted Washington State statutes and…

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Insurance Commissioner sends the Association Health Plan Market into shock

Shortly after the President signed health care reform legislation, many of us spent long hours parsing the thick bill to discern a place in a reformed market for association health plans. As I noted in prior articles (e.g., what-is-a-mewa-and-will-they-be-sent-to-the-health-care-reformatory ), for over fifteen years, the Washington small group market has been dominated by member governed…

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