ACA Title 1, Sec. 1402, Reduced cost-sharing for individuals enrolling in qualified health plans: “Ugly” – Removes most user out-of-pocket cost sharing. This section provides a fairly complicated “sliding fee schedule” for removal of out-of-pocket cost sharing for those whose income is up to 4 times the federal poverty limit. Why “4” times? Why not “3” or “2”, or just one times the poverty line levels? Also this provision sets a correspondingly complicated to administer maximum out-of-pocket cost limit (i.e., 100% reduction of out-of-pocket cost sharing for those below the federal poverty line, 2/3rds reduction for 100% to 200% of federal poverty limit, ½ cost reduction for those with 200%% to 300% of the federal poverty limit, and 1/3 rd for those with 300% to 400% of the federal poverty line. The federal government spent more than $80 million of research funds in the Rand Health Insurance Experiment to find out that removing out-of-pocket cost sharing was not a good idea and here we are providing a complicated way of calculating it and removing it. Also tying any cost sharing level to the federal poverty level is problematic. Are we using the individuals or families last year’s financial earning experience or this years? Bad policy leading to bad behavior and bad practices. “Bad” for user behavior and adds more unnecessary complexity to an already complex law.

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