ACA Title 1, Section 1343, Risk adjustment: “Bad” – Further undermines incentives for efficiency. This section provides a relatively easy way to avoid efficient claims administration while at the same time we as a nation are adopting and implementing ICD- 10 CM. This new set of diagnostic and procedural codes will triple to quadruple the number of separate possible diagnoses and medical procedures that insurers and health plans must adjudicate. The combination here is likely to further remove competitive forces from a significant percentage of the health plan and health insurers in the marketplace. Here again I would recommend triggers that are extreme just to limit the fairly adverse opportunity of using adverse selection to the health plans advantage.

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