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Comments to HHS on Medical Loss Ratio Requirements January 5, 2012 ,

The MLR rules as drafted discriminate against Health Savings Accounts (HSAs) and similar high-deductible health plans in a number of ways. These accounts provide employers, employees, and individuals with an option to purchase coverage with a larger deductible so that the polices function more like traditional “insurance” — covering medical expenses above a certain threshold. Policy holders save money because the premiums are generally lower than those for comprehensive health insurance. The Galen Institute respectfully requests that HHS exempt HSAs and other high-deductible health plans from the MLR requirement and that they ask the National Association of Insurance Commissioners to develop recommendations that would accommodate their unique financing arrangements.