Statement of Principles on Association Health Plans

National Patient Advocate Foundation shares the concerns regarding the increasing difficulty for employers to provide comprehensive health insurance benefits for their employees due, in large part, to rising health insurance premium costs. We note this is especially true for owners and employees of small businesses and workers who are self-employed. There is increasing interest among employers to enroll in Association Health Plans (AHPs) to enable small businesses and the self-employed to purchase health insurance coverage through business, professional or civic associations. Proponents contend that, by collectively leveraging the number of insured workers in a risk pool, AHPs would result in more affordable health insurance premiums and enable additional workers, and particularly workers with lower wages, to purchase health insurance coverage for themselves and their families. In response to these concerns, members of Congress have proposed legislation that would further govern and regulate AHPs.

National Patient Advocate Foundation will carefully consider all legislative proposals that will assist in reducing the number of Americans who lack private health insurance coverage and do not qualify for other federal or state health coverage programs. As Congress develops legislative proposals regarding AHPs, we respectfully request that the following concerns be given careful consideration:

Coverage Guidelines. AHPs should be prohibited from excluding industries that have a history of higher claims experience. Congress should establish minimum health insurance benefit packages and provide incentives for employers who offer additional benefits. AHPs should be prohibited from offering different health plans based on the geographic location of the employer. This is particularly important for those who live in rural areas of our country. AHPs should be prohibited from charging higher premiums for industries with a history of high claims experience. Furthermore, AHPs should be prohibited from increasing premium rates during a given plan year.

Pre-emption of State Regulation. Many states have enacted legislation that would provide all covered workers with certain minimum health insurance benefits. These benefits include access to emergency care services, mandatory, timely internal and external grievance and appeals procedures for denial of benefits, parity for coverage for mental health benefits with those of medical and surgical benefits, breast and cervical cancer screening, direct access to OB/GYN services and other benefits and services. States have also established strong oversight regulations to establish minimum solvency standards and to protect consumers against unfair claims practices and false or misleading advertising. National Patient Advocate Foundation believes that all AHPs should be required, at a minimum, to adhere to state health care laws and regulations in the states in which they operate. Plans should be required to adhere to state laws of the state in which the beneficiary resides.

Federal Oversight. National Patient Advocate Foundation is concerned that new federal legislation and regulations regarding AHPs could weaken existing state standards. We are concerned that if AHPs elect to self-insure, they could be exempt from state solvency requirements designed to ensure that insurance companies have sufficient resources to avoid financial failure. We are concerned that current federal requirements only require financial reporting when a health plan is near insolvency and permit AHP actuaries to certify solvency. We encourage Congress to carefully consider strengthening the current solvency standards for AHPs.

Impact on Employers Currently Offering Health Insurance Coverage. According to the Congressional Budget Office, companies that currently provide health insurance benefits could migrate to AHPs, thereby having the unintended result of increasing health insurance premiums for those employers who continue to purchase health insurance through traditional means. National Patient Advocate Foundation encourages Congress to carefully consider the impact that the expansion of AHPs will have on health care costs for employers who provide health insurance through traditional health plans.

Consumer Protections Must be in Place. Escalating premium costs must be limited to an annual increase only at the time of open enrollment. Consumers must be assured a timely appeal process in their state of residency if an external appeal is required.

Statement of Principles on Stem Cell Research

National Patient Advocate Foundation (NPAF) is an organization whose mission is to seek improved access to, and reimbursement for, healthcare services through both policy and legislative reform at the state and federal levels. Our mission is shaped by the experience of the patients we serve through our companion organization, the Patient Advocate Foundation. The Patient Advocate Foundation professional team includes case managers, oncology nurses, coding and billing specialists, licensed social workers, and debt crisis counselors who mediate and negotiate with insurers, employers, and creditors to resolve access to care, job retention, and debt crisis problems that result from a diagnosis of a chronic, life-threatening, or debilitating disease.

As an advocate for America's patient community, NPAF recognizes that stem cell research is critical to the fight against many life-threatening diseases. National Patient Advocate Foundation strongly supports permitting federal funds to be used for all forms of stem cell research, including adult stem cell research.

NPAF is committed to ensuring that patients receive access to the highest quality of medical care, which entails access to the latest therapies. NPAF therefore supports scientific research for therapeutic purposes that open the door to medical advancements that could not only save lives, but also enhance quality of life and alleviate suffering for patients.