HB1014, SB648, HB914 Health Insurance Legislation
Joint Committee on Financial Services

Joint Committee on Children, Families and Persons with Disabilities

The Massachusetts Health & Hospital Association (MHA), on behalf of our member hospitals, health systems, physician organizations, and allied healthcare providers, appreciates this opportunity to offer comments regarding a number of bills that seek to make changes to health insurance in the commonwealth.

MHA supports HB1014, which would provide a measure of safety to consumers purchasing association health plans. Under this bill, these plans would have to meet both minimum creditable coverage standards and be approved by the Division of Insurance (DOI). This would protect consumers from being underinsured and minimize uncompensated care for providers.

MHA opposes SB648. This bill would allow eligible individuals to purchase short-term medical plans, which are typically less than 12 months long. Once the plan ends, it would be considered a qualifying event and the person would be eligible to seek additional insurance coverage through the state’s insurance exchange. While such short-term insurance plans may be stopgap measures for a consumer who has no insurance, it’s not clear from this legislation whether these plans would have to meet minimum creditable coverage standards, or what carriers would be able to offer them. Use of short-term plans make it much harder for providers to track coverage of patients, file claims, and receive reimbursement, particularly if these are out-of-state carriers. Such plans would be administratively more burdensome and lead to an increase in underinsured individuals.

MHA opposes HB914. This legislation would dismantle the merged insurance market by removing eligible individuals and putting them back into the non-group health insurance marketplace. As merging the individual and non-group markets essentially lowered health insurance premiums for individuals by raising them for small businesses, breaking them apart would likely have the opposite effect, thereby increasing health insurance premiums for individuals and making the non-group market more volatile. Given the uncertainty over the Affordable Care Act and the potential destabilization of our healthcare system, this is no time to be disrupting the merged market. MHA also recognizes that the governor has established by executive order a Merged Market Advisory Council. Prior to creating new laws, MHA supports waiting for the report and recommendations issued by this body in April 2020, which includes analyzing the impact of any cross subsidization between the non-group and small group market segments. Therefore, MHA urges great caution when addressing the provisions of HB914.

Thank you for the opportunity to offer testimony on this matter. If you have any questions regarding this testimony, or require further information, please contact Michael Sroczynski, MHA's Senior Vice President of Government Advocacy at (781) 262-6055 or msroczynski@mhalink.org