Beginning in 2014, most employees at large companies will receive health care coverage either through their employers as most Americans do now, or through the new state health insurance exchanges. Therefore, large employers have a keen interest in having exchanges run efficiently and effectively run exchanges to ensure their employees have access to affordable and high quality care. However, as key exchange related deadlines rapidly approach, including a March 2013 deadline by which employers must provide their employees with detailed information regarding these exchanges, the Association is concerned about the slow progress by the federal government and the States in establishing exchanges and providing the necessary regulatory guidance. It is critically important that the federal government provide final regulations on the establishment, operation, and reporting requirements regarding exchanges as soon as possible so states can establish exchanges by PPACA’s deadlines and so that employers have enough time to implement the necessary system changes to meet all of their exchange related notice and reporting requirements.
Moreover, one of the Association’s chief concerns in the establishment of health insurance exchanges under PPACA is that the states, in establishing exchanges, may undermine the ability of multistate employers to uniformly design and administer health plans. This would result in subjecting multistate employers to numerous sets of operating requirements, a change that would be administratively burdensome and costly for them, and may make it unworkable for these employers to continue providing employer-sponsored benefits.