Dear Administrator Verma, Assistant Secretary Rutledge, and Deputy Commissioner Wielobob:
Thank you for the opportunity to comment on the proposed rule, “Short-Term, Limited Duration Insurance.”
The Cato Institute is a 501(c)(3) educational foundation dedicated to the principles of individual liberty, limited government, free markets, and peace. Its scholars conduct independent, nonpartisan research on a wide range of policy issues. To maintain its independence, the Cato Institute accepts no government funding. Cato receives approximately 80 percent of its funding through tax-deductible contributions from individuals. The remainder of its support comes from foundations, corporations, and the sale of books and publications.
On October 12, 2017, President Donald J. Trump signed Executive Order 13813, directing the Departments to reduce regulations and expand consumer choice in health insurance. Specifically, the president urged: “To the extent permitted by law and supported by sound policy, the Secretaries should consider allowing [short-term limited duration] insurance to cover longer periods and be renewed by the consumer.” On March 8, 2018, Secretary of Health and Human Services Alex Azar publicly lent his support to allowing short-term plans to offer renewal guarantees: “We’d like to see the ability to give people the option of renewability in whatever form we can have it.”