The "Public Charge" Rule, and What it Means for Immigrant Families

The Trump administration has released the long-awaited full version of the proposed changes to the "public charge" rule. The impact of the rule would be to force immigrant families to choose between receiving vital federally-funded health, food and housing assistance or being eligible to apply for green cards or visas.

Public Charge Rule.png

The proposed rule would disproportionately harm women and children, and would widen the definition of public charge to include four additional types of public benefits: 

  • non-emergency Medicaid coverage, 

  • premium and cost-sharing assistance for low-income people receiving Medicare Part D prescription drug coverage, 

  • SNAP food assistance and housing assistance (i.e. Section 8 voucher and public housing)

  • and a new income requirement; immigrants must make at least 125% of the Federal Poverty Level.

Medicaid expansion has helped tens of thousands of Marylanders get access to vital health services in our state. Many of those are immigrants. ANY attempt to limit access to Medicaid services is a huge step backwards.

For more information on the impact of this damaging and inhumane policy, read the Kaiser Family Foundation report which estimates that the proposed rule could lead to between 2.1 to 4.9 million Medicaid/CHIP enrollees to disenroll. 

The 60 Day Comment Period Ends 12/10/18

  • It is critical to voice your opinions about these proposed changes! The Protecting Immigrant Families coalition has created an action page with guidance and a template that you can use to submit your comments, which can be accessed here.

2019 Health Insurance Rates Approved - Good News!

Today, Governor Hogan held a press conference in Annapolis to announce the new rates approved by the Maryland Insurance Administration for the 2019 Maryland Health Benefit Exchange. As we reported earlier this week, the rates for 2019 health insurance plans came with a big surprise: both Kaiser Permanente and Care First LOWERED their requests thanks to a bipartisan effort to establish a state reinsurance program. 

The approved rates from carriers for the individual market are:

Rate Approval 2019.png

There is no doubt that this is great news for consumers, particularly the almost 200,000 who buy their own insurance.  And, this would not have happened without the hard work of elected officials, policy makers, consumer advocates and other stakeholders who were successful in putting a reinsurance program in place.

Consumers: Shop Carefully 

This year, more than ever, consumers will need assistance when they re-enroll or shop for new plans. They will need to carefully weigh the impact of rising deductibles, cost-sharing, and other aspects based upon their family's income and health needs. Those who do not get any financial assistance may find prices cheaper by buying off-exchange products. Fortunately, assistance is available through Maryland Health Connection and we encourage all consumers to go there for help.

Raising Your Voice Makes a Difference

In July, Consumer Health First submitted comments, with multiple organizations and individuals, on the original rate filings and then on the 1332 reinsurance program.  We know our voice made a difference and today the National Health Law Programissued a report - Public Comments Can Blunt Attacks on the Affordable Care Act and Medicaid - that confirms that. Today, even as we celebrate these low rates, we are moving forward with comments on plan certification standards and regulations for the reinsurance program. Then, there is all the work to be done to address the fact that the reinsurance program is a stop-gap measure with funding that will run out by 2021. By then we must have in place meaningful programs, such as an individual mandate and a public option, to keep health insurance affordable for all Marylanders. That is the least we can do to be truly effective. Please don't hesitate to contact us to raise issues that are of concern to you.

Reinsurance Program Waiver Approved!

Last week, Governor Hogan announced that CMS has approved Maryland's 1332 State Innovation Waiver for a reinsurance program that he described as "the largest in the United States." This is an important step towards lowering insurance premiums in the individual market. We congratulate all those who contributed to what the Governor described as a "common sense and bipartisan" effort. [Click the links to find the statement of Michele Eberle, MHBE Executive Director and coverage in the Baltimore Sun and Baltimore Business Journal.]

What are the next steps?

  •  Insurance carriers will resubmit their new rates with a hearing at the Maryland Insurance Administration scheduled for Monday, September 17.  CHF will be testifying at the hearing and expect to reiterate the points we first made in our July letter to Commissioner Redmer.
  •  By next week, the MHBE Board will address the issue of any duplicate payments CareFirst may receive under the Federal risk adjustment program and Maryland's reinsurance program. (Find the July 16 presentation to the Board here.) The Board's decision will impact the new proposed rates. CHF provided its comments on this and related issues at a hearing on July 26.
  • Regulations for the reinsurance program must be finalized before the end of the year. MHBE staff is to be commended for the very open process they carried out to get stakeholder input. In addition, to the comments cited above, CHF provided further input to the staff at the last of its four hearings.

As Delegate Pena-Melnyk said in the Baltimore Sun, this reinsurance program will "buy us time" to stabilize the individual market in the short term. We must now look at longer-term solutions and CHF will continue to be engaged in this process to assure Marylanders that health insurance premiums are equitable and affordable.

Health Insurance Rates: Moving Targets

On Thursday of last week, Consumer Health First submitted a letter signed by 40 individuals and organizations, to the Insurance Commissioner. In the letter, we expressed our concern over the exorbitant rates requested by CareFirst, in particular. We also provided a series of recommendations on steps the Commissioner could take to strengthen the rate review process and stabilize Maryland's individual health insurance market while providing more affordable rates for consumers. These comments will be the basis for the testimony to be given by Consumer Health First President,  Beth Sammis when the Maryland Insurance Administration holds their public hearing. 

Here come the moving targets:

  • That public hearing to get input on the published rates was rescheduled from today to Monday, July 30 from 1:00 to 4:00 pm.
  • On Saturday, CMS put risk adjustment payments on hold. It is unclear at this time what this action will mean for 2019 rates or the short- and long-term stability of the individual market. Read more: CHF letter and  an article in the New York Times.

For further background on the impact of federal actions and particularly the challenges for those above 400% Federal Poverty Level see this Washington Post article that cites the CMS Early Snapshot of 2018 effectuated enrollments and Trends in Subsidized and Unsubsidized Individual Health Insurance Market Enrollment.

For the latest on rates, the ACA and other breaking news, follow us on Facebook and Twitter @4ConsumerHealth

Raise Your Voice on Health Insurance Premiums - Sign Up Has Ended

In May, the Maryland insurance Administration  (MIA) released the insurance carriers' proposed rates for 2019 plans for the individual market. They range from Kaiser's 34.5% request to CareFirst's 91.4% for its PPO. If Maryland receives approval from the Centers on Medicare and Medicaid Services for its State Innovation 1332 Waiver application, then we would anticipate that the carriers will resubmit their requests in time for posting for Open Enrollment, which starts on November 1, 2018. 

Even with reductions in premiums, however, any approved increase will be on top of rates that are already unaffordable for many Marylanders. And, this will happen within the context of the Trump Administration's on-going efforts to sabotage the ACA.

Therefore, as the MIA conducts its rate review process, it is imperative that the Insurance Commissioner hear from consumers. As we have in the past, Consumer Health First is submitting substantive comments to the MIA and we will participate in the public hearing to be announced in early July. In the letter, we provide a number of recommendations on the rate review process as well as other steps we believe could address both short- and long-term challenges in providing affordable coverage options to those in the individual market.


  • Add Your Signature - The deadline is Thursday, July 5 at Noon. Your organization's signature on our letters has made a real difference in the past. Let's do it again.
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