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Policy & Advocacy

Shaping the future of healthcare through innovative policy solutions, expert analysis, and meaningful engagement with industry stakeholders.
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Model Legislation

Explore our legislative frameworks and policy proposals designed to enhance market stability and consumer protection in health insurance.

Policy Commentary

Read our expert analysis and recommendations on healthcare policy developments and market trends.

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Model Legislation

Premium Subsidy Modernization

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Proposal to transition ACA subsidies from IRS-managed tax credits to HHS-managed income-based advance subsidies for real-time accuracy and access.

Status: Shared With House

Transfers administration of APTC from IRS to HHS

Enables prior-year income verification for self-employed households

Supports real-time eligibility without tax filing penalties

Improves reconciliation accuracy and reduces improper payments

Small Employer Relief and Alignment

Proposal to revise the ACA's employer mandate by raising the large employer exmption threshold from 30 to 50 full-time equivalent employees, aligning it with ALE group market definitions.

Status: Shared with House. Proposed to Ways & Means

Raises employer mandate exemption threshold to exempt employer from paying penalty on first 50 FTEs instead of first 30.

Creates consistency with state small group market rules

Encourages ICHRA adoption among small-to-midsize employers

Reduces administrative burden and compliance risk for growing businesses

ICHRA Salary Reduction Fairness

Amends Section 125 of the tax code to allow pre-tax salary reduction for ACA marketplace premiums when opting out of APTC under an ICHRA and enrolling via an exchange.

Status: Draft Completed

Adds ยง125(f)(3)(C) carveout to support ICHRA salary reduction

Requires APTC opt-out to avoid double benefit

Aligns tax treatment for on-exchange and off-exchange enrollees

Empowers employees to choose marketplace plans with tax savings

Local Access Health Reimbursement Arrangement (LAHRA)

Concept proposal for a supplemental Health Reimbursement Arrangement that helps large employers address regional disparities in provider access by reimbursing out-of-network services, travel for care, and other benefits not covered by individual market plans. LAHRA would complement ICHRA by restoring employer flexibility in areas with narrow networks or limited plan options.

Status: Exploratory Phase

Designed for large employers (100+ FTEs) offering ICHRA in underserved regions

Provides a capped, employer-funded account to supplement ACA marketplace plans

Covers wraparound services like out-of-network care, travel expenses, or specialty access

Use-it-or-lose-it structure minimizes fiscal risk and maintains compliance boundaries

ICHRA Wrap Network Accessibility

Establishes statutory authority for employers to fund wrap benefits for narrow-network marketplace plans when using an ICHRA.

Status: Exploratory Phase

Creates framework for employer-funded wrap networks

Expands access for employees in network-inadequate regions

Supports emergency and specialty care gaps

Facilitates fair competition with traditional group plans

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