Want to help stop Trump's Short Term Plan Scam? You have until Monday night to chime in.

I've repeatedly written about how Donald Trump is still deperately trying to sabotage the ACA by any means necessary. Last year it was all about a combination of regulatory and legislative attacks, but aside from repealing the ACA's individual mandate (which was, admittedly, a pretty ugly blow), the GOP-held Congress was unsuccessful at tearing it down legislatively.

Therefore, for 2018, Trump has decided to double down on the regulatory side...and one of the main ways he hopes to achieve this is by opening up the floodgates on so-called "Short-Term, Limited Duration" policies, which aren't subject to most ACA requirements and therefore are a) free to siphon off healthy ACA-compliant enrollees into b) substandard healthcare plans which can leave thousands of people in dire straits.

As I've written before, I'm not necessarily opposed to short-term plans in all circumstances. There are certain people caught in certain situations for whom they're probably a logical choice for temporary coverage...but again, the emphasis is on temporary:

STLDs are similar to major medical policies in that they typically cover both hospitalization and at least some outpatient medical services, but unlike ACA-compliant policies, they often have significant benefit and eligibility limitations. STLD policies often either exclude are have significant limitations on benefits for mental health and substance abuse, do not have coverage for maternity services, and have limited or no coverage for prescription drugs. Policies also generally have dollar limits on all benefits or specific benefits and may have deductibles and other cost sharing that is much higher than permitted in ACA-compliant plans. Insurers of STLD policies typically use medically underwriting, which means that they can turn down applicants with health problems or charge them higher premiums. Policies also exclude coverage for any benefits related to a preexisting health condition: a backstop for insurers in case a person with a health problem otherwise qualifies for coverage and seeks benefits. Because STLD policies are not renewable, people who become ill after their coverage begins are generally not able to qualify for a new policy when their coverage term ends.

...Such "adverse selection" would raise the average cost of covering remaining individuals in ACA-compliant plans, leading to further premium increases in those policies. For people with pre-existing conditions who do not qualify for subsidies, the rising cost of ACA-compliant coverage could challenge affordability, especially for people with pre-existing conditions who have incomes that make them ineligible for premium subsidies.

The gimmick Trump is using to accomplish this is twofold: First, it would eliminate the "Short-Term" part of the definition. A few years back, the Obama administration issued a policy limiting these types of plans to no longer than 3 months per year...i.e., "short term" as you might imagine, designed purely to tide people caught in between jobs or some other life transition until they could enroll in a fully ACA-compliant policy. Trump's executive order from last fall removes the time constraint, thus allowing "short term" plans to run up to 364 days per year...making them not, by definition, "short-term".

In addition, the Obama administration prevented these policies from being renewed within the same calendar year...which makes perfect sense given that the whole point was to limit them to short periods of time (a 3-month limit is meaningless if you can just renew the same plan 3 more times that year). Trump's executive order would allow the no-longer-short-term plans to be renewed, once again negating the whole "limited duration" part of the title.

In other words, Trump wants to change "short-term, limited-duration" plans into "however long you want, non-ACA compliant" plans which leave enrollees vulnerable to the exact same types of abuses and coverage gaps found in pre-ACA policies, while simultaneously further damaging the ACA-compliant risk pool. A double whammy!

In any event, the HHS Dept. is accepting comments through midnight on April 23rd and will supposedly weigh these comments when deciding whether or not to actually unleash "Not-Short-Term, Not-Limited-Duration" non-ACA policies upon the land.

I'm not terribly hopeful that this will change anything, but I'd appreciate it if y'all would at least give it a shot. To do so, simply click this link and fill out the comment form.

It's at around 7,000 comments as of this writing; healthcare advocates are hoping to push it over the 10,000 mark by Monday night.

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