State Employer Groups on MLR Definitions

What They Are Saying – State Employer Groups:

Medical Loss Ratio Definitions

(Excerpts taken from comment letters submitted to NAIC or State Insurance Commissioners)

Indiana Chamber

  • “We ask that you carefully construct your MLR recommendations so that these rules do not result in premium increases, which would be detrimental to employer-sponsored health plans.”
  • “The Chamber appreciates your efforts on minimum loss ratio and urges you to approach the issue in a way that will minimize disruption and maximize the kind of activities that improve the quality and affordability of health care.”

The Business Council of New York State, Inc.

  • “It is essential that MLR recommendations not be narrowly constrained limiting New York employers’ flexibility in plan design and their ability [to] continue to offer affordable, quality coverage.
  • “The Business Council urges you to ensure that MLR recommendations recognize the value of health plans in driving quality and ensuring that consumers continue to have access to critical activities that improve the quality and the value of their care. This is very important in New York State – often recognized as a state with among the highest costs in the country – because employers have moved more aggressively into areas which have proven effective in managing employee wellness, allowing employers to better control plan costs without compromising quality.”
  • “The Business Council asks that those quality measures which are valuable to employers and their employees be included in the MLR calculation, including: wellness programs, disease management programs, fraud, waste and abuse activities, and certain health information technology tools. These measures provide valuable services to employees improving their health and the value of the care they receive. Failure to include these measures would increase costs for employers, and could jeopardize programs that are valuable to employees and beneficial to their health.”
  • “Many activities undertaken already, and many that will be required as a result of PPACA, include the developing, gathering, aggregation, and analysis of data in order to measure and incentivize quality, credentialing of providers, etc. We support such activities, and believe that both quality and transparency must be paramount in order to make health care more efficient, affordable, and to improve patient care.”
  • “Our objective is to ensure that New York employers are not burdened with regulations which so narrowly define an MLR as to cause plan design changes which will drive up costs even further.”

Ohio Chamber of Commerce

  • “The MLR definitions could have a considerable impact on our member’s ability to provide coverage and result in additional premium increases that would be detrimental to employer-sponsored health plans in Ohio. Therefore, the Ohio Chamber urges you, and the other NAIC members, to carefully consider your recommendations regarding these rules.”
  • “Wellness and prevention initiatives have demonstrated that they lead to lower costs for consumers by improving health and wellbeing.”
  • “There are several types of programs that employers and insurers implement that are crucial to keeping the cost of insurance premiums as low as possible. We believe capturing these programs in the MLR definition of quality activities will provide an incentive for these programs to be maintained.”

Virginia Chamber of Commerce

  • “[We are] writing because the MLR definitions could have a considerable impact on our members’ ability to provide coverage. We ask that you carefully construct your MLR recommendations so that these rules do not result in premium increases which would be detrimental to employer-sponsored health plans.”
  • “…we urge you to recommend the following:
    • “Wellness and prevention be included under the umbrella of quality initiatives…[w]ellness and prevention initiatives have been demonstrated to lead to overall lower costs for consumers by improving their health and wellbeing, and none of them should be considered ‘administrative.’”
    • “Include all quality, fraud and abuse, and cost control initiatives that clearly improve quality and patient safety in the definition of ‘activities that improve health care quality.’
    • “We are concerned that not capturing these programs in the MLR definition of quality activities means that insurers will have a strong disincentive to spend on these activities as they well increase administrative costs and reduce medical expenses.”
  • “We appreciate your efforts on minimum loss ratio and urge you to approach the issue in a way that will minimize disruption and maximize the kind of activities that improve the quality and affordability of health care.”

Association of Washington Business: Washington State’s Chamber of Commerce

  • “This issue is of great concern to the members of the Association of Washington Business as the final rules could significantly impact our member’s ability to continue providing health care coverage to their employees.”
  • “…[we] ask that you carefully construct the MLR recommendations so that the rules do not result in premium increases, as such would be highly detrimental to employer-sponsored health plans.”

Additionally, the Connecticut Business & Industry Association, Maine State Chamber of Commerce, Missouri Chamber of Commerce and Industry, and the Wisconsin Manufacturers & Commerce all have sent letters on the MLR issue.

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