Comments on risk adjustment policies in the 2024 payment rule

Health Insurance
Editor's note:

This comment letter is part of the USC-Brookings Schaeffer Initiative for Health Policy, which is a partnership between Economic Studies at Brookings and the University of Southern California Schaeffer Center for Health Policy & Economics. The Initiative aims to inform the national health care debate with rigorous, evidence-based analysis leading to practical recommendations using the collaborative strengths of USC and Brookings. This comment was submitted to the Department of Health and Human Services on January 30, 2023.

Matthew Fiedler and Timothy Layton provided comments to the Department of Health and Human Services (HHS) on the 2024 Notice of Benefit and Payment Parameters. The authors’ comments relate to the state option to request a reduction in individual and small group market risk adjustment transfers of up to 50%. They encourage HHS to move ahead with fully eliminating this option for the 2025 plan year and to reject Alabama’s request to implement a reduction for the 2024 plan year. The authors also argue that eliminating the reduction will not undermine competition in Alabama’s markets, as the state fears.

Read their full letter here.

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