On September 5th and September 9th, respectively, MassAHU's Legislative Counsel provided testimony during Public Hearings on the Determination of the Employer Fair Share Contribution and Revisions to the Minimum Creditable Coverage Regulations.

Dan Foley presented MassAHU's testimony to the Division of Health Care Finance and Policy relative to the Adoption of Amendments to 114.5 CMR 16:00 - The Determination of the Employer Fair Share Contribution (FSC). In his statement in opposition to the changes to the Fair Share Contribution regulation, Mr. Foley stressed that these proposed changes to the FSC regulations, as implemented under the healthcare reform law, runs counter to the understanding and agreement reached with the business community as to what was expected of employers and their responsibilities under the new law. He went on to state that these changes represent a cost-shifting onto employers by requiring employers to meet both the 25% enrollment test for full time employees (FTE) and the payment by the employer of at least 33% of the premium for FTEs' will cost small businesses thousands of dollars more. In addition, requiring that the FSC reports be filed quarterly will result in an administrative nightmare.

Mr. Foley provided to the Board of the Commonwealth Health Insurance Connector Authority, MassAHU's testimony on the 956 CMR 5.00 Draft Revisions to Minimum Creditable Coverage (MCC) Regulations. While some of the changes to the MCC were needed for clarification, Mr. Foley opposed the revisions that expanded the standards that would be required for health plans to meet the MCC and increase the cost of health insurance for small businesses. In fact, one of the revision's limits the availability of certain products to employers and individuals. He stated that "we cannot continue to overburden employers with additional mandates and requirements". MassAHU specifically opposed the requirement that prescription drug coverage be mandated to meet MCC. MassAHU also opposed the change to the regulations that deal with High Deductible Health Plans (HDHP) and Health Savings Accounts (HSA) by requiring that these plans must meet MCC standards. We suggested that no change be made to the section of the regulation dealing with HDHP and HSA's.

Thank you to those MassAHU brokers and others who provided testimony on these important issues.