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ABC Oct. 4 filed comments as part of the Small Business Coalition for Affordable Healthcare regarding the exchange-related provision in the Patient Protection and Affordable Care Act (PPACA).

In the comments, the coalition pointed out the need for a responsive and sustainable exchange that attracts and caters to small businesses, their employees and families who need access to more plans, greater transparency and affordable options.  The coalition noted that affordability is paramount, in addition to allowing employers and employees to compare and choose a policy that meets their needs; providing a standardized application; and providing small businesses with the option to pay for health insurance for multiple employees, policies and carriers with one check.

“Small business owners remain committed to working as partners to develop an insurance marketplace that is simple, efficient and responsive to their consumer needs,” the comments stated. “We deeply believe that the input of small business will be critical to ensuring that the foundation of the exchange can address the needs of employers.”

The comments pointed out that the greatest consideration that needs to be made is how to structure an exchange so that employers providing coverage to their employees can ensure the needs of their workforce are being met in the most efficient and least burdensome way possible.  In order to achieve that, the coalition suggested that businesses be allowed to aggregate payments from multiple sources; that the process be simplified so businesses are not absorbed by administrative tasks; and that the exchange board consists of a geographically diverse group that includes employees, health insurance regulators, small businesses and the self-employed, and others.

The coalition listed a number of factors that will affect the success of an exchange.  Since small businesses on average pay about 18 percent more for health insurance than larger businesses, affordability is extremely important and can be achieved by constructing a minimum threshold of health services and carefully assessing the value versus the cost when expanding those services.  In addition, the coalition called for allowing employers to provide their employees with a wider range of choices for health plans.  Also, the coalition said that enrollment should be easy with little paperwork or administrative burdens and must be accessible, even to business owners that do not use a computer. 

The coalition also recommended that a Small Business Advocacy Review Panel be convened to assess how these regulations will impact small businesses.  If a significant impact is found on a substantial number of small businesses, the coalition recommended the agencies halt all rules until alternative arrangements can be proposed.  The coalition also recommended that more research be conducted before making any decisions about expanding the size limits in the exchange from the limit of 2-50 employees that currently exists.