ABC, as part of the Small Business Coalition for Affordable Healthcare, submitted comments Dec. 21, 2012, on a Department of Health and Human Services (HHS) proposal regarding essential health benefits (EHB) and determining actuarial value. 

When the proposal was released Nov. 20, 2012, Washington Council Ernst & Young released a Legislative Update (PDF) with additional information on these topics and HHS issued a fact sheet. 

In its comments, the coalition expressed concern with the regulatory analyses provided in HHS’ proposed rule, noting that it substantially underestimates the impact the proposed rule will have on premiums of health insurance products purchased by small businesses. 

“These analyses state that the benefits of the EHB justify the costs, but do not recognize that individuals and small employers will face additional costs,” the comments stated. “While the direct cost of regulation will impact insurers, these costs will be passed along to small business indirectly.”

The coalition also commented on cost-sharing requirements in the proposal and the actuarial value calculation for determining level of coverage. The comments are available in PDF format. 

The Small Business Coalition for Affordable Healthcare represents more than 150 small business associations and has spent more than a decade working to increase access to and affordability of private health insurance.