Commentary: House Bill Would Block Trump Administration Rules on Health Waivers That Weaken Pre-Existing Condition Protections
End Notes
[1] Sarah Lueck and Jessica Schubel, “Understanding the Affordable Care Act’s State Innovation (“1332”) Waivers,” Center on Budget and Policy Priorities, updated September 5, 2017, https://www.cbpp.org/research/health/understanding-the-affordable-care-acts-state-innovation-1332-waivers.
[2] Katie Keith, “Feds Dramatically Relax Section 1332 Waiver Guardrails,” Health Affairs blog, October 23, 2018, https://www.healthaffairs.org/do/10.1377/hblog20181023.512033/full/ and Timothy S. Jost, “Using the 1332 State Waiver Program to Undermine the Affordable Care Act State by State,” Commonwealth Fund, October 30, 2018, https://www.commonwealthfund.org/blog/2018/using-1332-state-waiver-program-undermine-affordable-care-act-state-state.
[3] State Relief and Empowerment Waivers, guidance, Federal Register, Vol. 83, No. 206, October 24, 2018, https://www.govinfo.gov/content/pkg/FR-2018-10-24/pdf/2018-23182.pdf.
[4] The paper is not official regulation or guidance, but it illustrates how the Administration thinks states could implement the changes in guidance. “Section 1332 State Relief and Empowerment Waiver Concepts,” discussion paper, Centers for Medicare & Medicaid Services, Center for Consumer Information & Insurance Oversight, November 29, 2018, https://www.cms.gov/CCIIO/Programs-and-Initiatives/State-Innovation-Waivers/Downloads/Waiver-Concepts-Guidance.PDF.
[5] “American Health Care Act, Congressional Budget Office Cost Estimate,” Congressional Budget Office, March 13, 2017, https://www.cbo.gov/system/files?file=115th-congress-2017-2018/costestimate/americanhealthcareact.pdf.
[6] “Remarks by Administrator Seema Verma at the CMS National Forum on State Relief and Empowerment Waivers,” CMS press release, April 23, 2019, https://www.cms.gov/newsroom/press-releases/speech-remarks-administrator-seema-verma-cms-national-forum-state-relief-and-empowerment-waivers.
[7] Sarah Lueck, “Key Flaws of Short-Term Health Plans Pose Risks to Consumers,” Center on Budget and Policy Priorities, September 20, 2018, https://www.cbpp.org/research/health/key-flaws-of-short-term-health-plans-pose-risks-to-consumers.
[8] Sabrina Corlette, “What’s in the Association Health Plan Final Rule? Implications for States,” State Health & Value Strategies blog, June 22, 2018, https://www.shvs.org/whats-in-the-association-health-plan-final-rule-implications-for-states/.
[9] Sarah Lueck, Tara Straw, and Shelby Gonzales, “Health Care Rule Changes Will Harm Consumers,” Center on Budget and Policy Priorities, April 12, 2018, https://www.cbpp.org/research/health/health-care-rule-changes-will-harm-consumers.
[10] Sarah Lueck, “What Level of Coverage Will Health Reform Likely Provide? The Basics of Actuarial Value,” Center on Budget and Policy Priorities, October 13, 2009, https://www.cbpp.org/research/what-level-of-coverage-will-health-reform-likely-provide-the-basics-of-actuarial-value.
[11] Waivers for State Innovation, guidance, Federal Register, Vol. 80, No. 241, December 16, 2015, https://www.gpo.gov/fdsys/pkg/FR-2015-12-16/pdf/2015-31563.pdf.