Yesterday marked the deadline for comments to be submitted on the Trump Administration’s proposed short-term scam insurance. A wide variety of health care experts – including doctors, insurance exchange operators, insurance companies, analysts, and more than 100 patient groups – continue to make clear their strong opposition to the Administration’s proposal. Here’s what they had to say:

American Medical Association: Proposed Rule “Would Result In Substandard, Inadequate Health Insurance Coverage.” “We believe the proposed rule, however, would culminate in plans being offered that fall far short of maintaining crucial state and federal patient protections, disrupt and destabilize the individual health insurance markets, and result in substandard, inadequate health insurance coverage.” [Forbes, 4/22/18]

American Cancer Society Cancer Action Network, American Heart Association, American Liver Foundation, American Lung Association, Arthritis Foundation, Autism Speaks, Chron’s & Colitis Foundation, Cystic Fibrosis Foundation, Epilepsy Foundation, Family Voices, Hemophilia Federation of America, Leukemia & Lymphoma Society, Lutheran Services in America, March of Dimes, Mended Little Hearts, NAMI, National Health Council, National Multiple Sclerosis Society, National Organization for Rare Disorders, National Patient Advocacy Foundation, National Psoriasis Foundation: “Given The History Of Discrimination And Inadequate Coverage Within Short-term Limited-duration Plans, We Are Deeply Concerned That The Proposed Rule Could Seriously Undermine The Key Principles Of Access, Adequacy, And Affordability That Are The Underpinnings Of Current Law – And Put Those We Represent At Enormous Risk.” “Given the history of discrimination and inadequate coverage within short-term limited-duration plans, we are deeply concerned that the proposed rule could seriously undermine the key principles of access, adequacy, and affordability that are the underpinnings of current law – and put those we represent at enormous risk. We urge the Departments to withdraw the proposed rule until the needs of our populations are met and instead, to focus on stabilizing the individual insurance markets and lowering premiums for QHPs.” [ACS-CAN, 4/23]

American Academy Of Family Physicians: “Short-Term, Limited-Duration Plans Will Not Provide Meaningful Insurance Coverage.” “The AAFP strongly opposes the proposed rule since it allows plans to sell low-value insurance policies that could subject patients to catastrophic medical bills and medical bankruptcy. We oppose efforts to exempt short-term, limited-duration plans from consumer protections such as covering preexisting conditions or essential health benefits (EHBs). Furthermore, we oppose allowing any plans to establish caps on annual benefits since limiting benefits can expose patients to extraordinarily high out-of-pocket costs… The AAFP has significant concerns with these proposals since short-term, limited-duration plans will not provide meaningful insurance coverage. While these plans could increase the availability and affordability of services, we do not think doing so should come at the expense of meaningful insurance coverage.” [AFP, 4/18]

America’s Health Insurance Plans: “Not A Replacement For Comprehensive Coverage.” “‘We are concerned that this proposed rule will lead to more people being uninsured and under-insured, and to higher costs in the long run,’ AHIP chief executive Matt Eyles said. ‘Short-term plans can provide an important temporary bridge for Americans who are transitioning between plans. But they are not a replacement for comprehensive coverage.’” [Forbes, 4/23]

Alliance Of Community Health Plans: “The Proposed Rule Will Undermine Consumer Protections.” “The proposed rule will undermine consumer protections because short-term, limited duration plans do not require coverage of essential health benefits or coverage of pre-existing conditions. There is a substantial risk that consumers will not understand the coverage limitations that accompany short term plans. Contracts for medical coverage can be quite complex, and consumers may assume that essential health benefits are covered by short-term, limited duration plans, but for a shorter period of time. This could lead to consumers purchasing health insurance that is inadequate for their medical needs, potentially resulting in personal bankruptcy and an increase in uncompensated care for hospitals and other facilities. There is evidence of this connection between coverage and personal financial status: A Consumer Reports study found that increased health care coverage over the past several years was associated with a reduction by half in the number of personal bankruptcy filings. With the increased use of short-term, limited duration plans, we anticipate a troubling reversal of this trend.” [ACHP, 4/19/18]

American Cancer Society-Cancer Action Network: “We Believe That The Proposed Rule Should Be Withdrawn.” “We are very concerned about policies that would expand access to STLD policies because these products are exempt from important consumer protections, such as prohibitions on lifetime and annual dollar limits, limits on the use of pre-existing condition exclusions, and the prohibition on medical underwriting. These protections are key to ensuring that individuals with cancer (including those in active treatment and survivors) have access to quality health care needed to treat their disease. Without these protections, individuals could find themselves enrolled in policies that fail to provide coverage of medically necessary services. We believe this proposed rule should be withdrawn unless the needs of the patient community have been met.” [ACS CAN, 4/20/18]

American Hospital Association And Federation Of American Hosptials: “Concerned That The Result Will Be Increased Uncompensated Care.” “The American Hospital Association and the Federation of American Hospitals said the proposed rule, if finalized, would drain hospitals’ resources. The federation, which represents investor-owned hospitals, said its members ‘are concerned that the result will be increased uncompensated care, particularly for patients who need uncovered services or treatment for preexisting conditions.’” [Modern Health Care, 4/23]

Association for Community Affiliated Plans: Rule WIll Harm Consumers And Health Care Providers. “The Association for Community Affiliated Plans, a group representing safety-net plans that cover Medicaid, Medicare special-needs and marketplace members, warned that finalizing the rule as proposed would harm consumers and healthcare providers. The group warned that sellers of short-term plans have been known to rescind coverage as soon as an individual becomes ill and files a substantial claim. The space has been riddled with patient lawsuits over unpaid medical bills. ACAP pointed to the recent 42-state investigation into the business and marketing practices of Tokio Marine’s HCC Life subsidiary, a short-term medical insurer. Earlier this month, HCC Life reached a settlement to pay a fine of $5 million. The insurer is also prohibited from selling short-term plans for at least five years. ACAP also warned that skimpy short-term plan benefits would lead to increased uncompensated care.” [Modern Health Care, 4/23]

Heather Korbulic, Silver State Health Insurance Exchange Director: “Deeply Concerned” About Proposed Rule. “The head of Nevada’s health insurance exchange is ‘deeply concerned’ about a proposed federal rule change that would extend the length of short-term health plans, saying in a Friday letter to the Centers for Medicare and Medicaid Services that the policy will likely result in higher premiums for people who purchase insurance on the exchange… Korbulic is just one of many in the health-care field nationwide who has expressed concern that approving the federal rule will siphon off the healthiest individuals from the individual market, leaving behind a sicker, more expensive population. In the letter to CMS, Korbulic wrote that individuals with pre-existing conditions or who anticipate needing medical care will likely remain on the exchange where they can purchase plans with comprehensive health benefits but will likely face premium increases.” [Nevada Independent, 4/23]

American Heart Advocacy: Patients “Will Suffer If This Rule Becomes Law.” “Today is the deadline to tell HHS not to extend short-term health plans. The outcome is clear — Patients living with CVD, stroke survivors and others with pre-existing conditions will suffer if this rule becomes law.” [American Heart Advocacy, 4/23/18]

Matt Slonaker, Utah Health Policy Project Executive Director: Short-Term Plans Designed To Weaken ACA. “Matt Slonaker is the executive director of the Utah Health Policy Project. He said the new plans are a way to weaken the health law. ‘Unfortunately what is happening here is the short-term insurance idea is being used as a guise to erode some of the protections of the Affordable Care Act,’ Slonaker said.” [KUER, 4/23]

Tanji Northrup, Assistant Commissioner of the Utah Insurance Department: Short-Term Plans Could Increase Premiums By Double-Digits. “Tanji Northrup is the Assistant Commissioner of the Utah Insurance Department. She says these new plans will pull people out of ACA plans and make them more expensive. ‘There will definitely be increases because of pulling those healthy people out of the traditional market,’ Northrup said… Northrup says if these short-term plans go through, Affordable Care Act rates could increase by double-digits. She says no insurers in Utah have contacted her department yet to develop these new plans.” [KUER, 4/23]

Mario Molina, Former CEO of Molina Healthcare: Hopefully You Already Have Kids Because Maternity Care Won’t Be Covered. “Hopefully, you had kids already, because under the short-term health plan expansion encouraged by an executive order signed last year, covered maternity care vanishes in 100% of plans analyzed by [the Kaiser Family Foundation]” [Mario Molina, 4/23/18]

Blue Cross Blue Shield Association: Significant Concerns. “[BCBS] has significant concerns that allowing consumers to stay on these plans for a full year ‘would cause rates to increase for those who need or want comprehensive health insurance coverage.'” [Washington Post, 4/24/18]

Larry Levitt, Kaiser Family Foundation Senior Vice President: “These Short-Term Policy Brochures Read Like An Obstacle Course Of Exclusions.” [Washington Post, 4/23/18]

Kaiser Family Foundation: Analysis: Most Short-Term Health Plans Don’t Cover Drug Treatment or Prescription Drugs, and None Cover Maternity Care. “A new Kaiser Family Foundation analysis of short-term, limited duration health plans for sale through two major national online brokers finds big gaps in the benefits they offer. Through an executive order and proposed new regulations, the Trump Administration is seeking to encourage broader use of short-term, limited duration health plans as a cheaper alternative to individual market plans that comply with the Affordable Care Act’s requirements. Repeal of the individual mandate penalty – which currently applies to people buying short-term plans – is also expected to boost enrollment starting next year. The analysis examines 24 distinct short-term insurance products currently marketed in 45 states and the District of Columbia through eHealth or Agile Health Insurance. It finds: 43 percent do not cover mental health services; 62 percent do not cover substance abuse treatment; 71 percent do not cover outpatient prescription drugs; and none of the plans cover maternity care.” [Kaiser Family Foundation, 4/23]

Washington Post: Trump Proposal Could Mean Healthy People Save On Insurance While Others Get Priced Out. “The Trump administration’s proposal to build up short-term health insurance plans as a ‘lifeline’ for people who can’t afford Affordable Care Act coverage could split the insurance market in two, siphoning young, healthy people into cheaper, more minimal plans — while those who remain in ACA plans face premiums that spiral upward even faster… The effects of that policy change, combined with zeroing out the individual mandate’s financial penalty in 2019 will be harmful to the most vulnerable patients, according to more than 100 patient groups and many health policy wonks.” [Washington Post, 4/23]

Las Vegas Sun: Health Experts Concerned About Risks Of Limited-duration Health Plans. “People would be able to stay on a type of sub-par temporary health plan longer under a proposed Trump administration rule, sparking a concern that the plans won’t give consumers sufficient coverage. The proposal would lift the cap on short-term limited duration plans from six months to just under a year to give more options to consumers who cannot afford the rising cost of health care, according to the Department of Health and Human Services and other agencies involved. The plans can be much cheaper, but do not carry Obamacare-required benefits such as coverage for preexisting conditions.” [Las Vegas Sun, 4/23]

The Hill: Insurer Group Issues Warning On Trump Administration’s Short-Term Health Plan Proposal. “The nation’s largest trade group for health insurance companies is sounding the alarm on a proposal from the Trump administration that would expand the sale of plans that cover fewer services.  America’s Health Insurance Plans (AHIP) says the proposal could lead to more people being uninsured or underinsured and result in higher health-care costs in the long run.” [The Hill, 4/23]

Forbes: Health Insurers: Trump’s Short-Term Plans Will Trigger Loss Of Coverage. “The Trump administration’s proposed cheaper short-term plans may not provide adequate coverage and would trigger an increase in the number of uninsured and under-insured Americans, say health insurers that would be expected to sell such coverage. Through their lobby, America’s Health Insurance Plans, companies Monday were the latest to weigh in on the Trump administration’s proposed rule on short-term plans… Health insurance companies Monday morning issued their critique of the Trump administration’s proposal, joining a parade of doctor groups concerned about any effort to reduce coverage or pare benefits.” [Forbes, 4/23]

Healthcare Dive: Payer Trade Groups Slam Short-term Health Plan Proposal. “The Alliance of Community Health Plans (ACHP) and America’s Health Insurance Plans (AHIP) both slammed CMS’ proposal to expand short-term, limited duration (STLD) insurance plans, saying the proposed rule would undermine key consumer protections, lead to higher premiums in the individual market and jeopardize market stability.  The proposed rule, pushed by the Trump administration as a way to increase access to cheaper plan alternatives and sidestep the Affordable Care Act, would allow consumers to purchase plans for up to 12 months that do not adhere to federal rules for individual health insurance. STLD plans can charge those with pre-existing conditions more and may not cover ACA essential health benefits such as prescription drug coverage. The insurance lobbies argued that other policy mechanisms would be more effective at improving the individual health insurance market.” [Healthcare Div, 4/23]

Washington Times: Insurers’ Lobby Asks Trump To Curtail Short-term Insurance Plan. “Health insurers’ main lobbying group urged the Trump administration Monday to curtail its push to let Americans get around Obamacare by purchasing cheap ‘short-term’ plans for a full year, saying consumers will be left with skimpy coverage. Matt Eyles, the incoming president and CEO of America’s Health Insurance Plans, also said the plan — if it proceeds — should not be enacted until 2020, so insurers have time to plan for a reconfigured marketplace.” [Washington Times, 4/23]

Washington Examiner: Trump-Backed Short-Term Health Plans Have Big Gaps In Benefits, Analysis Finds. “Short-term health insurance plans that the Trump administration wants to expand don’t offer the same benefits of Obamacare plans, a new analysis found. A study from the health research firm Kaiser Family Foundation looked at how short-term plans cover the same benefits as Obamacare. The healthcare law requires plans sold on Obamacare’s insurance exchanges to cover 10 essential health benefits that include mental health services, prescription drug coverage, and maternity care. The Trump administration is seeking to expand the duration of the short-term plans from 90 days to nearly 12 months. These plans are cheaper than Obamacare plans because in part they do not have to cover as many benefits.” [Washington Examiner, 4/23]

Forbes: Doctors Attack Trump’s Short-Term Health Plans Ahead Of Comment Deadline. “An effort by the Trump administration to introduce cheaper short-term health insurance plans is under attack by physician groups who see the plans eliminating benefits and putting patient health at risk. The American Academy of Family Physicians and other doctor groups have unleashed detailed critiques of Trump’s effort to introduce cheaper health insurance with skimpier benefits ahead of a Monday deadline at 5 pm to provide public comments to the administration.” [Forbes, 4/22]

Vox: If You Need Prescriptions Or Maternity Care, You Won’t Like Trump’s Short-term Insurance Plans. “Short-term plans are much less likely to cover mental health and substance abuse treatment or prescription drugs — all of which must be covered by ACA plans. What is insurance, you might ask, if it doesn’t cover medications? This is also a setback for the ongoing effort to have mental health and substance abuse treated as equal to other physical health needs.” [Vox, 4/23/18]

Healthcare Dive: Report Finds Most Short-term Plans Don’t Cover Maternity, Substance Misuse Care. “A Kaiser Family Foundation report argues that recent efforts to promote short-term plans could have an adverse effect on the Affordable Care Act-compliant individual market, creating higher premiums for compliant plans and potentially leaving a greater number of people uninsured.  The expansion of short-term plans, along with the elimination of the individual mandate penalty, could also make it difficult for people who need behavioral health services and substance misuse treatment, which aren’t typically covered benefits under those plans. The Trump administration’s plans for short-term expansion would primarily impact the middle class, as lower-income people are protected from premium increases through the use of federal subsidies, KFF said.” [Healthcare Dive, 4/24]

Insurance News Net: Trump Administration Implored To Curtail Short-Term Plan. “Health insurers, patient groups and Senate Democrats implored the Trump administration Monday to curb or cancel its push to let Americans get around Obamacare by using cheaper, short-term health plans for a full year, saying the plan would destabilize the insurance markets and increase the number of uninsured… More than 100 patient-advocacy groups protested the proposal Monday, the final day to submit comments to HHS, noting the full-year plans could duck Obamacare rules requiring robust coverage or preventing insurers from denying sicker patients or charging them more than healthy ones.” [Insurance News Net, 4/24]

Modern Health Care: Insurers, Hospitals Warn Short-term Plans Aren’t The Answer. “Several health insurance and hospital associations urged HHS to spike the proposed rule to expand access to short-term, limited-duration health insurance, warning it would lead to higher premiums for Affordable Care Act-compliant plans and more uncompensated care delivered at hospitals. Meanwhile, stakeholders in the short-term insurance market encouraged HHS to finalize the proposed rule allowing the sale of short-term plans with durations of up to 12 months, saying the extension would lead to lower premiums and more options for consumers. It is clear those stakeholders would see more customers and higher revenue if the proposed rule is finalized.” [Modern Health Care, 4/23]

Washington Examiner: Healthcare Groups Plea With Trump Administration To Nix Short-Term Insurance Plan Rule.  “A wide array of doctor, insurer, and other major healthcare groups pleaded with the Trump administration to nix plans to expand short-term insurance plans… Healthcare groups say in comments to the proposed regulation, which were due Monday, the plans are no better than “junk insurance” that erode patient protections. The regulation would expand the duration of the short-term plans from 90 days to nearly 12 months.” [Washington Examiner, 4/23]

47 Senators: The Proposed Rule Will “Increase Costs And Reduce Access To Quality Coverage For Millions Of Americans, Harm People With Pre-Existing Conditions, And Force Premium Increases On Older Americans.” “If finalized, the rule could increase costs and reduce access to quality coverage for millions of Americans, harm people with pre-existing conditions, and force premium increases on older Americans. This rule expands the sale and marketing of “junk plans” that exclude basic benefits including hospitalization, prescription drugs, mental health services, substance abuse treatment, and maternity care. We urge you not to finalize the proposed rule and instead work with us to ensure that all American families have choices of affordable, meaningful health care coverage.” [State of Reform, 4/23]