Earlier this fall, I noted that HHS had granted waivers to 30 organizations that provide “mini-med” health insurance plans, allowing them to continue to provide policies with benefit maximums far below the $750,000 minimum annual maximum required as of 2011 under the PPACA (this amount will increase over the next few years, becoming unlimited by 2014).
As of last week, the number of waivers granted by HHS has grown to 222, and more than 1.5 million plan enrollees will continue to be covered next year by policies that provide limited benefits, despite the fact that those policies do not conform to the PPACA rules. Some of the exempted plans cover only a few workers, but some have thousands of enrollees.
In order to be granted a waiver, the health plan in question will have to clearly notify enrollees that the policy does not meet the new federal guidelines because of the benefit maximums, and the specific benefit caps included in the policy will have to be clearly stated. In addition, the enrollees will have to be notified that the plan has been given a waiver, but that the waiver is only for one year. It’s possible that some people who are enrolled in limited benefit plans might not be aware of the limitations on their coverage, and providing them with the specifics about the waiver might encourage them to shop around for more comprehensive health insurance.
In some cases, the limited benefit plans might actually provide decent coverage, but fall short of the $750,000 minimum annual maximum required in 2011. But waivers have also been granted for policies that wouldn’t even cover a single day in the hospital, and it’s hard to see how that sort of “coverage” is providing much of a safety net for employees (and providing a safety net is what insurance is supposed to do).
I do understand the dilemma HHS was faced with regarding mini-med plans. If the employers and policies in question were unable to upgrade the coverage to meet the new requirements and would have opted instead to terminate the coverage, the plan enrollees would have been left completely uninsured (although that isn’t much worse than having a policy with a $2000 annual cap…). But allowing hundreds of limited benefit plans to continue to operate seems to be in conflict with the spirit of health care reform. Hopefully the one year waiver will give the plans in question time to come up with a solution that allows them to continue to offer coverage to their employees (perhaps with longer waiting periods before new hires can enroll, in order to address the issue of providing health insurance in industries with high turnover?) without having to use such restrictive benefit caps. I just hope this doesn’t turn into a perpetual waiver cycle, with new “one year” waivers being granted as the old ones expire.