Letter to Treasury, HHS, and Department of Labor Supporting Proposed Rule Expanding HRAs

The Honorable Steven Mnuchin
Secretary
U.S. Department of the Treasury

The Honorable Alex Azar
Secretary
U.S. Department of Health & Human Services

RE: REG-136724-17

Dear Secretaries Mnuchin, Acosta and Azar:

The Council for Affordable Health Coverage (CAHC) welcomes the opportunity to comment on the notice of proposed rulemaking (NPRM) entitled Health Reimbursement Arrangements and Other Account-Based Group Health Plans (REG-136724-17) issued by the U.S. Departments of the Treasury, Labor, and Health and Human Services. CAHC is a broad-based alliance with a singular focus: bringing down the cost of health care for all Americans. Our membership represents a broad range of interest-organizations representing small and large employers, manufacturers, retailers, insurers, patient groups, and physician organizations.

Employers are the largest purchasers of health care services and coverage in this country, and they are leading the way in innovation and the shift toward value in the private market. While premiums in the employer market, where the majority of Americans receive their coverage, have remained relatively stable compared to the individual market, costs are rising more than twice as fast as wages. This is largely due to rapid increases in the cost for medical services, and federal mandates and regulatory burdens under the Affordable Care Act (ACA). In fact, these rising costs are a primary contributor to premium growth, and as costs continue to outpace economic growth, it makes coverage less affordable and more out of reach for millions of Americans.

CAHC supports efforts to expand options in the health care marketplace for employers of all sizes and their employees. Consumer directed health products (CDHPs), such as health reimbursement arrangements (HRAs), are an important strategy to both pay for an reduce health costs. We strongly supported and advocated for the qualified small employer HRA (QSEHRA) program in the 21st Century Cures Act (P.L. 114-255) to allow small businesses to offer an HRA without penalty if certain qualifications were met.