Trump admin releases 4 "concepts" for states to consider under the #ACA 1332 waiver program. cms.gov/newsroom/press… @GtownCHIR So what are the 4 concepts?
'Course, they don't mention fact that 1332 guidance released earlier this month is probably in violation of APA (state proposals that take advantage of looser guardrails likely face legal challenge) brookings.edu/blog/usc-brook…
(1) state could re-direct ACA subsidies to personal accounts, from which consumers could draw $ for premiums, cost-sharing.
(2) State could design/run their own subsidy program that could deviate from current federal eligibility/ income-based structure for APTCs, CSRs.
(3) States could direct ACA subsidies to support purchase of alternative plans (catastrophic plans are mentioned).
(4) State could use 1332/pass through money to support "risk stabilization" through reinsurance or high risk pool
Far from being 1332 "templates" as initially advertised, these "concepts" are remarkably vague. Not much for states to go on, here.
.@CMSGov says they're releasing them to "spur innovative" ideas. Reminds states that any proposal still has to meet the ACA's guardrails on affordability, comprehensiveness, deficit neutrality...
Some more detail on the 1332 concepts, here, but still a lot of unanswered questions for states cms.gov/CCIIO/Programs…
