Hours ago, Illinois Gov. Bruce Rauner (R) vetoed legislation that would have subjected enrollees in short-term health insurance plans to higher deductibles, higher administrative costs, higher premiums, and lost coverage. The vetoed bill would have blocked the consumer protections made available in that market by a final rule issued earlier this month by the U.S. Department of Health and Human Services, and would have (further) jeopardized ObamaCare's risk pools by forcing even more sick patients into those pools.
Short-term plans are exempt from federal health insurance regulations, and as a result offer broader access to providers at a cost that is often 70 percent less than ObamaCare plans.
Rather than allow open competition between those two ways of providing health-insurance protection, the Obama administration sabatoged short-term plans. It forced short-term plan deductibles to reset after three months, and forced consumers in those plans to reenroll every three months, changes that increased administrative costs in that market.
The Obama administration further subjected short-term plan enrollees to medical underwriting after they fell ill -- which meant higher premiums and cancelled coverage for the sick. Prior to the Obama rule, a consumer who purchased a short-term plan in January and developed cancer in February would have coverage until the end of December, at which point she could enroll in an ObamaCare plan. The National Association of Insurance Commissioners complained that the Obama rule required that her coverage expire at the end of March -- effectively cancelling her coverage and leaving her with no coverage for up to nine months. The Obama administration stripped consumer protections from this market by expanding medical underwriting after enrollees get sick -- something Congress has consistently tried to reduce.
Earlier this month, HHS restored and expanded the consumer protections the Obama administration gutted. It allowed short-term plans to cover enrollees for up to 12 months, and allowed insurers to extend short-term plans for up to an additional 24 months, for a total of up to 36 months. These changes allow short-term plans to offer deductibles tallied on an annual basis, rather than deductibles that reset every three months. They spare enrollees and insurers the expense of re-enrolling every three months. Most important, they allow short-term plans to protect enrollees who get sick from medical underwriting at least until they again become eligible to enroll in an ObamaCare plan the following January.
Indeed, HHS clarified that because the agency has no authority to regulate standalone "renewal guarantees" that allow short-term plan enrollees who fall ill to continue paying healthy-person premiums, "it may be possible for a consumer to maintain coverage under short-term, limited-duration insurance policies for extended periods of time" by "stringing together coverage under separate policies offered by the same or different issuers, for total coverage periods that would exceed 36 months." As HHS Secretary Alex Azar explains, this helps ObamaCare:
Our decision to allow renewability and separate premium protections could also allow consumers to hold on to their short-term coverage if they get sick, rather than going to the exchanges, which improves the exchange risk pools.
I made that very argument in my comments on the proposed rule.
Illinois law automatically adopts whatever rules and definitions the federal government creates for short-term plans. If Illinois legislators had just done nothing, millions of Illinois residents automatically would have had a health insurance option that is more affordable and provides better coverage than ObamaCare.
But this is Illinois.
In their infinite wisdom, Illinois legislators passed legislation that once again would have exposed short-term plan enrollees higher deductibles, higher administrative costs, higher premiums, and cancelled coverage. The bill would have:
- Required that initial contract terms for short-term plans last no longer than six months. It further provided that such plans could be extended for no more than six additional months.
- Mandated that consumers who wish to keep purchasing consecutive short-term plans go uninsured for 60 days. Some consumers would inevitably develop expensive conditions during that period, and therefore be left with no coverage until the next ObamaCare open enrollment period.
- Prohibited renewal guarantees. The legislation specifically cut off this option. As a result, it would have dumped every single short-term plan enrollee with an expensive illness into the Exchanges. Ironically, Illinois legislators who thought they were bolstering ObamaCare actually passed a bill that would have sabotaged it.
Thankfully, Gov. Rauner stopped this ignorant, ridiculous effort to deny consumer protections to short-term plan enrollees. All eyes now turn to California, where Gov. Jerry Brown (D) must sign or veto legislation that would deny medical care to those who miss ObamaCare's open enrollment period -- by banning short-term plans altogether.
The usual narrative is that Democrats support consumer protections and Republicans oppose them. Today’s short-term plans final rule flips that narrative: Republicans are expanding consumer protections, and Democrats are opposing them.
Today’s rule reverses a 2016 Obama rule. The Obama rule reduced consumer protections in short-term plans by exposing sick patients to medical underwriting. Before that rule, consumers could purchase short-term plans that lasted 12 months. If they developed a serious illness, their plan could cover them until the next ObamaCare open enrollment period, when they could purchase coverage without medical underwriting. The Obama rule restricted short-term plans to 3 months. It prohibited “renewal guarantees” that protect enrollees who fall ill from medical underwriting when they purchased a new short-term plan. As a result, the Obama rule left short-term plan enrollees who got sick with no coverage for up to 9 months: those who purchased a plan in January, and developed a serious illness in February, would lose their coverage at the end of March, and have no coverage until the following January. (Source: NAIC) This was by design: the Obama administration wanted to expose sick people in short-term plans to medical underwriting and lost coverage as a way of forcing consumers to buy ObamaCare coverage instead. That’s at least a little messed up.
Today’s rule allows short-term plans to last 12 months and offer renewal guarantees. It therefore allows short-term plans to protect the sick from medical underwriting for an additional 9 months—indeed, “issuers may offer coverage under a short-term, limited-duration insurance policy for up to a total of 36 months, without any medical underwriting or experience rating beyond that completed upon the initial sale of the policy”—and allows renewal guarantees to protect them from medical underwriting indefinitely. Protecting the sick from medical underwriting has long been a goal of Congress.
So, to recap, Republicans are expanding consumer protections, and Democrats are opposing an expansion of consumer protections.
Weird, isn’t it?
Any day now, the Trump administration will release a final rule allowing greater consumer protections in so-called "short-term, limited duration insurance," a category of health insurance Congress exempts from federal health insurance regulations, including ObamaCare regulations. In comments I filed on the proposed version of the Trump administration's rule and an accompanying Wall Street Journal oped, I explained some but not all of the benefits of allowing these consumer protections. What follows is updated and new information about the benefits of allowing those consumer protections.
In 2016, the Obama administration arbitrarily prohibited certain consumer protections in short-term plans. First, it exposed sick consumers to underwriting and loss of coverage by shortening the maximum duration of short-term plans from 12 months to 3 months. Second, it prohibited "renewal guarantees" that would protect consumers who develop expensive illnesses from ever facing underwriting or losing their coverage.
Last year, President Trump urged the Department of Health and Human Services to allow short-term plans to last 12 months and to allow consumers to bridge together consecutive short-term plans with "renewal guarantees" that protect them from being re-underwritten after they get sick. With ObamaCare premiums soaring and the consulting firm Avalere warning of "substantial increases" in ObamaCare premiums for 2019, these consumer protections would mean "consumers could purchase health-insurance protection for 90% less than the cost of the average ObamaCare plan." Renewal guarantees would keep people with expensive conditions out of ObamaCare plans, thereby improving ObamaCare's pools and reducing the cost of ObamaCare. Along the way, allowing these consumer protections would "increas[e] transparency in government and provid[e] voters and policymakers with better information about the cost of the ACA."
Thirty-five senators sent a letter to the Trump administration citing my regulatory comments and urging the administration to implement both changes. But there's more.
Critics Agree: Expanding Short-Term Plans Would Cover More Americans
The American Action Forum has a roundup of economic projections of the impact of allowing these consumer protections. Every organization that has modeled these changes, including those that oppose them, has found they would increase the number of Americans with health insurance.
- Congressional Budget Office: 1 million additional insured by 2023
- Urban Institute: 1.7 million additional insured in 2019
- Commonwealth Fund: as many as 2.2 million additional insured by 2020
- Center for Health and Economy: 2.3 million additional insured by 2020
These projections indicate that expanding short-term plans would produce significant social-welfare gains. The Urban Institute, for example, projects 2.2 million consumers would leave ObamaCare plans for short-term plans because they would "prefer STLD to ACA-compliant plans." This suggests a large increase in consumer welfare. Similar welfare gains would result from as many as 1.7 million previously uninsured Americans enrolling in short-term plans with the proposed consumer protections.
Protecting Conscience Rights
An often-overlooked benefit of allowing these consumer protections in short-term plans is that they would free consumers to avoid coverage they do not want, including coverage that may violate their religious convictions.
ObamaCare requires all health insurance plans to cover all FDA-approved forms of birth control. This requirement forces devout Catholics and others to choose between going without health insurance or paying to support a practice they believe is an offense against God. The Trump administration has taken steps that protect conscience rights for some employers. But these changes do not protect all employers, much less all consumers.
Since short-term plans are exempt from ObamaCare's contraceptives mandate, allowing them to offer 12-month terms and renewal guarantees would give Catholics and others full freedom to purchase secure health insurance without violating their religious beliefs.
As Susan Marquis and colleagues noted prior to the creation of ObamaCare, “Purchasers derive value from having the range of choices that the individual market offers.” The range of health insurance choices would expand, and consumer welfare would increase not captured by premium reductions, if the Trump administration allows short-term plans to offer consumers a wider range of secure coverage options.
Improving ObamaCare's Risk Pools
Finally, renewal guarantees would improve ObamaCare's risk pools by keeping potentially millions of expensive patients out of ObamaCare plans.
There is a sizeable if underappreciated literature showing that renewal guarantees keep premiums low, and therefore provide secure coverage, to patients after they develop expensive medical conditions. In "Incentive-Compatible Guaranteed Renewable Health Insurance Premiums" (Journal of Health Economics, 2006), Bradley Herring and Mark Pauly explain the concept of renewal guarantees:
A person initially in good health who develops a chronic illness may expect to have above-average expenses in subsequent years. If the annual insurance premium is set proportional to expected expense in each year, someone who contracts a multi-year condition would face a substantial and unexpected jump in premiums—something public policy finds undesirable and something which a risk-averse person would prefer to avoid. A potential solution to this problem is for the insurance policy purchased when the individual is still in good health to contain a guaranteed renewability (GR) provision which stipulates that no insured’s future premium for the given policy will increase more than any other insured’s premium increases. Thus, people who unexpectedly become high-risk will pay the same premium as those who remain low-risk.
In "Guaranteed Renewability in Insurance" (Journal of Risk and Uncertainty, 1995), Mark Pauly, Howard Kunreuther, and Richard Hirth explain, "Effectively, [with a renewal guarantee,] the consumers initially prepay enough premiums to cover the excess losses of everyone who becomes a high risk." See also John Cochrane, "Time-Consistent Health Insurance" (Journal of Political Economy, 1995).
Researchers have found considerable evidence that, prior to ObamaCare, widespread renewal guarantees in the individual market worked as theory predicts: they provided secure, long-term insurance for those who develop expensive illnesses. In "Pooling Health Insurance Risks" (American Enterprise Institute, 1999), Pauly and Herring found that renewal guarantees make premiums affordable for high-cost patients:
The overarching message from these data is that nongroup premiums do vary with risk, but not nearly as strongly as would be consistent with vigorous risk rating. Perhaps more important, they do not vary at all with risk as measured by chronic conditions...This is not to deny that some people pay very high premiums for their coverage, and that some of the people who do so are high risks. Apparently, however, many high risks do not pay higher-than-average nongroup premiums.
In "Individual Versus Job-Based Health Insurance: Weighing The Pros And Cons" (Health Affairs, 1999), Mark Pauly, Allison Percy, and Bradley Herring write:
In other words, there was substantial cross-subsidization of high-risk by low-risk persons in the individual insurance market in a period in which there was only minimal state regulation. Premiums do rise with risk, but the increase in premiums is only about 15 percent of the increase in risk. Premiums for individual insurance vary widely, but that variation is not very strongly related to the level of risk.
From an economic viewpoint, the main problem with risk rating is...that the occurrence of an extended illness may subject buyers to the risk that their premium may jump, potentially by several multiples. While a thousand-dollar jump in one’s annual premium may seem trivial compared with the high medical bills the insurance will cover, risk-averse persons would prefer to avoid it. There is a simple way to do so: Buy insurance when healthy but pay extra for guaranteed renewability or protection from cancellation.
The evidence indicates that even before the Health Insurance Portability and Accountability Act (HIPAA) became effective in 1997, the majority of individual policies contained this feature. The intent of guaranteed renewability can be circumvented (for example, by canceling all policies in a class), but it usually is not, for the obvious reason that sale of this feature requires that it be effective most of the time...In recent years some states have required guaranteed renewability, but it is apparent that this was a common feature of individual (not small-group) policies even before it was required. The presence of guaranteed renewability may account in part for the moderate increase in paid premiums with risk, noted earlier.
In "How Private Health Insurance Pools Risk" (NBER Reporter, 2005), Pauly writes:
Although there have been some anecdotes about insurers slipping out of their policy provision to renew coverage at group average premiums for high risks by canceling the coverage entirely, we conclude that on average guaranteed renewability works in practice as it should in theory and provides a substantial amount of protection against high premiums to those high risk individuals who bought insurance before their risk levels changed. The implication is that, although there are some anecdotes about individual insurers trying to avoid covering people who become high risk (for example, by canceling coverage for a whole class of purchasers), the data on actual premium-risk relationships strongly suggest that such attempts to limit risk pooling are the exception rather than the rule.
Indeed, Pauly concludes, guaranteed renewability does such a good job at protecting the sick from higher premiums, regulations that prohibit charging higher premiums to the sick (i.e., community rating) don't change much:
We find that regulation modestly tempers the (already-small) relationship of premium to risk, and leads to a slight increase in the relative probability that high-risk people will obtain individual coverage. However, we also find that the increase in overall premiums from community rating slightly reduces the total number of people buying insurance. All of the effects of regulation are quite small, though. We conjecture that the reason for the minimal impact is that guaranteed renewability already accomplishes a large part of effective risk averaging (without the regulatory burden), so additional regulation has little left to change.
In "Consumer Decision Making in the Individual Health Insurance Market" (Health Affairs, 2006), Susan Marquis et al. find the lower premiums that renewal guarantees make available to the sick made the individual market "a source of long-term coverage for a large share of subscribers." This occurs because enrollees who purchase coverage and then later become sick “are not placed in a new underwriting class.” The authors attribute this to renewal guarantees: “We also find that there is substantial pooling in the individual market and that it increases over time because people who become sick can continue coverage without new underwriting.” The authors also found that, despite underwriting, “a large number of people with health problems d[id] obtain coverage” in the individual market pre-ObamaCare. The authors conclude:
Our analysis confirms earlier studies' findings that there is considerable risk pooling in the individual market and that high risks are not charged premiums that fully reflect their higher risk. Moreover, guaranteed renewal and underwriting only at initial enrollment appear to help promote pooling to some extent, and they protect subscribers from financial consequences associated with changes in their health status.
In "Risk Pooling and Regulation: Policy And Reality in Today’s Individual Health Insurance Market" (Health Affairs, 2007), Pauly and Herring found that as a result of renewal guarantees:
Analysis of new data on the relationship between and premiums and coverage in the individual insurance market and health risk shows that actual premiums paid for individual insurance are much less than proportional to risk, and risk levels have a small effect on obtaining coverage. States limiting risk rating in individual insurance display lower premiums for high risks than other states, but such rate regulation leads to an increase in the total number of uninsured people. The effect on risk pooling is small because of the large amount of risk pooling in unregulated [i.e., guaranteed-renewable] individual insurance...
As the MEPS data show, the predicted high risks (above the median) had both high expected expenses (before the fact) and high actual expenses (after the fact); they were roughly four times higher compared with the bottom half. But the premiums that higher-risk people actually paid were only, on average, about 1.6 times those of lower-risk people...At least half of their higher expected expense appears to be pooled, even in the individual market...
Premiums were definitely far from proportional to risk, so there was a substantial amount of risk pooling present...Although in these data people of a given age and sex with chronic health conditions paid higher premiums than people without such conditions, individual insurance, through guaranteed renewability or some other device, pooled 84.5–88.5 percent of the risk...
Yet again in "Incentive-Compatible Guaranteed Renewable Health Insurance Premiums" (Journal of Health Economics, 2006), Herring and Pauly find "evidence that guaranteed renewability provisions appear to be effective in providing protection against reclassification risks in individual health insurance markets."
Perhaps the strongest evidence that renewal guarantees will keep high-cost patients out of ObamaCare's risk pools comes from "How Risky Is Individual Health Insurance?" (Health Affairs, 2008), in which Mark Pauly and Robert Lieberthal find that guaranteed-renewable, individual-market insurance often does a better job than employer-sponsored insurance of providing secure coverage to patients with high-cost illnesses. As the below graph shows, high-cost patients with guaranteed-renewable coverage are roughly half as likely to end up uninsured as high-cost patients with small-group coverage, and unlike employer-sponsored coverage, the risk of losing guaranteed-renewable coverage does not rise with health risk.
The more high-cost patients that renewal guarantees can keep from losing their non-ObamaCare plans--including, as I discuss in my regulatory comments and Wall Street Journal oped, those enrolled in employer plans--the fewer high-cost patients will enroll in ObamaCare plans and the more stable and less costly ObamaCare will be.
Giving consumers the choice of purchasing renewal guarantees, either in conjunction with a short-term plan or as a standalone product protecting enrollees from re-underwriting in that market, would produce significant benefits well in excess of any costs. It would increase the number of Americans with health insurance, allow Americans to purchase insurance that respects their religious beliefs, and improve ObamaCare's risk pools.
If you aren't paying attention to the debate over short-term health insurance plans, you should. It's a mixed-up, muddled-up, shook-up world where Republicans are pushing to expand consumer protections, Democrats are fighting to block them, and the public debate has it exactly backward.
In this morning's Wall Street Journal, I explain:
ObamaCare premiums keep skyrocketing. Rate hikes as high as 91% will hit many consumers just before Election Day. Maryland insurance commissioner Al Redmer warns ObamaCare is in “a death spiral.”
So-called short-term health plans, exempt from ObamaCare’s extensive regulations, are providing relief. Such plans often cost 70% less, offer a broader choice of providers, and free consumers to enroll anytime and purchase only the coverage they need.
But there’s a downside. When enrollees fall ill, either their premiums spike or they lose coverage, leaving an expensive ObamaCare plan as the only alternative. Markets solved that problem decades ago via “renewal guarantees,” which allow enrollees who get sick to keep paying the same premiums as healthy enrollees.
For more than two decades, Congress has consistently tried to prevent sick patients from being to medical underwriting. Yet in 2016, the Obama administration did exactly the opposite. It issued a regulation that exposed enrollees in short-term plans to medical underwriting after they got sick:
In 2016, in an effort to force people into ObamaCare plans, the Obama HHS shortened the maximum duration for short-term plans from a year to three months and banned renewal guarantees. The National Association of Insurance Commissioners complained this reduced consumer protections and exposed the sick to greater risk, including the risk of having no coverage.
The Trump administration has proposed reversing the Obama rule and allowing short-term plans to offer both 12-month terms and renewal guarantees that allow enrollees who get sick to keep paying the same premiums as healthy enrollees (i.e., no more underwriting). Both of these proposals are consumer protections that would protect the sick from medical underwriting and in some cases protect the sick from losing coverage entirely.
Believe it or not, Democrats are opposing these consumer protections! I am tempted to say their opposition is inexplicable, but it's all-too explicable. Democrats want to prevent short-term plans from offering these consumer protections because they fear consumers will find short-term plans more attractive than ObamaCare. Democrats are literally trying to stop Republicans from expanding consumer protections because they would rather protect ObamaCare.
Democrats want to make short-term plans as unattractive as possible because they worry that otherwise, ObamaCare's risk pools will suffer as healthy people leave ObamaCare plans for short-term plans. That was the purpose of limiting short-term plans to just three months. But back in 2016, the National Association of Insurance Commissioners explained the Obama rule's attempt to cripple short-term plans won't help ObamaCare:
If the concern is that healthy individuals will stay out of the general pool by buying short-term, limited duration coverage there is nothing in this proposal that would stop that. If consumers are healthy they can continue buying a new policy every three months. Only those who become unhealthy will be unable to afford care, and that is not good for the risk pools in the long run.
Indeed, Democrats' opposition to allowing short-term plans to offer renewal guarantees betrays a fundamental misunderstanding of how renewal guarantees work. As I explain in my Wall Street Journal oped:
Prohibiting renewal guarantees hurts ObamaCare’s risk pools by forcing enrollees who develop expensive illnesses to switch to ObamaCare plans. Allowing renewal guarantees would improve ObamaCare’s risk pools by giving expensive patients an affordable, secure alternative—just as renewal guarantees kept expensive patients out of state-run high-risk pools before ObamaCare.
How many expensive patients could renewal guarantees keep out of ObamaCare's risk pools? More than you might think. Allowing short-term plans to offer renewal guarantees would also free insurers to sell renewal guarantees as a stand-alone product--at a cost roughly 90 percent below that of ObamaCare plans. Insurers could market these products not only to the 50 million or so non-elderly people without employer-sponsored insurance. They could also offer them, as they had just begun to do in 2009, to the 175 million Americans with employer-sponsored coverage. Renewal guarantees could thus improve the outlook of ObamaCare's risk pools by keeping potentially millions of expensive patients out of ObamaCare plans.
Presented with the opportunity to expand consumer protections in a manner that could even save taxpayers money, many administration wouldn't bother with annoying questions about whether they actually have the legal authority to do it. Fortunately, HHS has such authority, as I explain at length in comments I filed on the Trump administration's proposed rule on short-term plans. Long story short, HHS can allow renewal guarantees in short-term plans because federal law grants the agency no authority to regulate renewal guarantees, much less to ban them.
If HHS acts swiftly to allow short-term plans to offer renewal guarantees, it can make affordable, secure health insurance options available right about when ObamaCare's next round of premium hikes will hit consumers.
In a recent letter to the Trump administration, leading congressional Democrats ask the administration not to allow protections for enrollees in short-term health plans.
Yes, you read that right. Dated April 12, the letter comes from Sens. Patty Murray (WA) and Ron Wyden (OR), as well as Reps. Frank Pallone (NJ), Bobby Scott (VA), and Richard Neal (MA), each the top Democrat on a different congressional committee with jurisdiction over health care. They ask the administration to withdraw in its entirety a proposed rule that, if implemented, would offer significant protections to enrollees in so-called "short-term limited duration plans."
The administration has proposed lengthening the maximum term for such plans from 3 months to 12 months, which had been the limit for nearly two decades before the Obama administration shortened it. The administration has also asked for public comments (due April 23) on whether it should allow insurers to offer short-term plans with "renewal guarantees"—a consumer protection that allows enrollees who develop expensive illnesses to continue paying low, healthy-person premiums.
The letter asks the administration to "withdraw the proposed rule in its entirety," which would block those consumer protections. These Democrats literally want to prevent short-term plans from giving consumers the peace of mind from knowing they will be covered for an entire year. Worse, these Democrats want to prohibit short-term plans from offering a consumer protection that protects the sick from premium spikes.
The reason for this animosity toward short-term plans is rather clear: ObamaCare supporters don't want the competition. Federal law exempts "short-term limited duration plans" from ObamaCare and other federal health-insurance regulations. Short-term plans free consumers to purchase only the coverage they want, rather than have ObamaCare force them to buy coverage they don't want, including coverage for things they may find morally repugnant. ObamaCare supporters do not want consumers to have that freedom, because when consumers leave ObamaCare coverage for short-term plans, ObamaCare premiums will reflect more and more of the cost of that law.
It is the height of irony for Democrats to call consumer-oriented short-term plans "junk plans" when ObamaCare is making coverage worse for the sick. One study found ObamaCare's preexisting-conditions provisions penalize insurers $6,000 per opioid addict they enroll—so whichever health plan offers the best coverage pays the most penalties—and that ObamaCare is making coverage for opioid addiction and other ailments worse and worse as a result. At the same time, the law is causing premiums to rise so rapidly they double every few years. The only "junk" plans here are ObamaCare's.
Expanding short-term health-insurance plans would give consumers the freedom to vote with their feet. Democrats don't want consumers to have that freedom, because they know what the outcome of that vote will be. ObamaCare would continue to crumble, and Democrats would have to work with Republicans to replace it. The letter from Murray, Wyden, Pallone, Scott, and Neal provides all the more reason for the Trump administration to allow short-term plans to offer renewal guarantees.
Congress appears unwilling to provide any sort of ObamaCare relief.
But did you know states can exempt their residents from ObamaCare’s costliest regulations simply by letting them purchase insurance licensed by U.S. territories—i.e., across state lines?
Or that the Trump administration has the authority to provide even more relief from ObamaCare than last year’s Cruz Compromise would have, just by reversing HHS’ administrative ban on renewal guarantees in short-term plans?
Well, now you do. From my latest oped in The Hill:
States and the Trump administration each have the power to deliver relief from ObamaCare while Congress dithers.
In 2014, the Obama administration reversed its interpretation of ObamaCare and found the law’s costliest regulations do not apply in U.S. territories. As a result, states can provide relief from ObamaCare by freeing individuals and employers to purchase health insurance licensed by American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, or the U.S. Virgin Islands.
The Obama administration’s reversal also provides a model for the Trump administration. HHS has the authority to and should reverse its administrative ban on short-term health plans offering “renewal guarantees.” Ending that ban would dramatically reduce premiums for the vast majority of consumers in the individual market, even as ObamaCare premiums continue to skyrocket. Conservative states and states with vulnerable GOP members like Florida, Illinois, and Pennsylvania would see the largest premium reductions.