By Chip Kahn, President and CEO, Federation of American Hospitals
Ghost Busters. The current debate over the existence of “phantom enrollees” in marketplace health plans is wasted space and a dead-end distraction as Congress contends with the impending expiration of the marketplaces’ enhanced premium tax credits.
Here’s how it goes: The argument centers on the notion that millions of enrollees are mistakenly, or fraudulently, enrolled in marketplace plans because many are not using health care services. Further, the argument contends that the existence of these “phantom” insureds is a reason why the expiring enhanced tax credits should not be extended. Those who disagree say significant percentages of enrollees not accessing care is commonly the case in group coverage – and is an important fact that makes health care risk pools work. Premiums paid by all help fund care for those who are sick at any given time, providing security for the entire pool from the risk of needing costly care. The fact that many are not using health care services at any given time does not constitute an issue.
This issue of “phantom enrollees” is yesterday’s news. Due to overwhelming program integrity measures made by both the Trump Administration and the current Congress, any previous existence of “phantom enrollees” whether true or not, or problematic or not, should have no bearing on the current debate around extending the enhanced tax credits.
Roll the tape. This past year the Trump Administration:
-Stiffened requirements for verifying income and eligibility, especially for those seeking premium tax credits,
-Repealed the monthly special enrollment period for low-income individuals asserting it vulnerable to fraud,
-Put new requirements in place – including fees – to confirm eligibility and to prevent unintentional or fraudulent re-enrollment,
-Standardized open enrollment, limiting mid-year enrollments that could be tied to anticipated health needs,
-Cracked down on marketplace agents and brokers, including setting up steps for firing those who engage in fraudulent activities,
-Denied tax credits if enrollees failed to reconcile prior tax credits or were non-compliant,
-Put in place ongoing audits of consumers, agents, and brokers to ensure integrity.
On top of all those measures, Congress added legislative weight behind the Administration’s enforcement and fraud prevention policies. Congress also granted HHS more authority to develop and enforce fraud detection and prevention.
Experts across the landscape – regardless of ideology – agree these measures will depress coverage and future enrollments. Some argue for the better, while we are concerned that the overwhelming scope of these measures could mean that many Americans will arbitrarily lose coverage. Regardless, the fact is these measures address the concerns of those sounding the alarm about “phantom enrollees.”
You can’t have it both ways. The issue of extending the enhanced tax credits is clearly beyond the context of the dated arguments over “phantom” insureds. Extended tax credits would not start until 2026 and right now there are new program integrity measures in place that – for 2026 and beyond – will remove millions of enrollees from marketplace plans. We shouldn’t further penalize the Americans remaining in marketplace plans by letting the expiration of the tax credits impede the affordability of coverage.
Protecting Americans’ coverage benefits us all. It provides peace of mind and health security to millions of Americans, it helps our communities stay strong, and it keeps our economies productive. The small business owners, gig workers, and blue-collar Americans making just over the poverty line without employer-sponsored insurance need the option to buy quality, affordable coverage.
Without question extending the enhanced premium tax credits is a critical path to ensuring access to affordable health coverage for millions. If these tax credits were to lapse, premiums could double for families across the country, they won’t be able to afford coverage, and millions of hardworking men, women, and kids will lose the peace of mind that health insurance provides for the many “what ifs” life could throw their way.
The need is too great and the issue too important to base the extension of tax credits debate on an outdated issue.