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House Panel Advances Bill That Would Temporarily Halt ObamaCare’s Employer Mandate

Click here to read article online.

By The Hill | July 12, 2018

The House Ways and Means Committee on Thursday approved legislation that would chip away at ObamaCare, including a measure that would temporarily repeal the law’s employer mandate.

The bill sponsored by GOP Reps. Devin Nunes (Calif.) and Mike Kelly (R-Pa.) would suspend penalties for the employer mandate for 2015 through 2019 and delay implementation of the tax on high-cost employer-sponsored health plans for another year, pushing it back to 2022.

Congress repealed the penalty associated with the individual mandate last year, but it doesn’t take effect until 2019.

“I think it’s fair, if we relieve the burden for individuals, that we stand with our small and mid-sized companies,” Kelly said.

Powerful lobbying groups like the U.S. Chamber of Commerce have pushed for a repeal of the employer mandate.

The other measure, sponsored by Reps. Peter Roskam (R-Ill.) and Michael Burgess (R-Texas), would allow the use of ObamaCare’s tax credits for plans outside of the exchanges in the individual market. It would also allow anyone to purchase a catastrophic plan — plans that are cheaper but cover fewer services and are currently only available for those under the age of 30.

The bill “provides a much needed offramp for pressure people are feeling right no in terms of premiums increases and limited choices,” Roskam said.

Both measures advanced on party-line votes.

Democrats opposed the bills, saying they would cost too much and destabilize ObamaCare.

Dickerson Update July 12, 2018

The weather is hot, and your sales will be too when you partner with Dickerson. This week we’re bringing you the latest from Anthem, Blue Shield, Oscar and EaseCentral.

Click here to view as a webpage.

Group Updates

Anthem

Anthem Blue Cross announced that Community Hospital Long Beach has closed and discontinued all services effective July 3, 2018. Letters have been mailed to members who sought services or had a family member receive services in the last 12 months, as well as to physicians with admitting privileges at the hospital.

Don’t forget that Anthem Blue Cross has a statewide hospital network of over 300 acute care facilities. To find a participating hospital in a specific area, click the ‘Find a Doctor’ feature available at www.anthem.com/ca.

For more information such as how members are affected, alternate hospitals and post-termination care, please click here.

Blue Shield

Blue Shield will be closing the San Mateo Blue Shield Administered Direct Contract HMO (San Mateo DCHMO) on August 31, 2018. Members who are currently assigned to San Mateo DCHMO will be transitioned to an alternate IPA for an effective date of September 1, 2018.

The alternate IPAs are Brown and Toland Medical Group, Dignity Health Medical Network Sequoia, Hill Physicians San Francisco, Palo Alto Medical Foundation (PAMF) and PAMF Mills Peninsula Division. The closure of this HMO affects Small Business, Core, Premier and CalPERS.

Members who are affected by this update can call the member services number on their Blue Shield member ID card to self-select a PCP or IPA, or they can go online to the find a doctor tool.

For more information on this closure, please click here.

Oscar Health

Oscar Health has just released its Q4 rates, and changes are outlined below.

Q4 Rate Increase Rating Area 15
(North/East LA)
Rating Area 16
(South/West LA)
Rating Area 18
(Orange County)
Bronze 0.3% to 0.7% 1.2% to 1.6% 6.3% to 6.7%
Silver -0.4% to 0.0% 0.5% to 0.9% 5.5% to 5.9%
Gold -0.6% to -0.4% 0.4% to 0.5% 5.4% to 5.6%
Platinum -0.8% to -0.7% 0.2% to 0.2% 5.2% to 5.2%

Oscar Health Q4 rates are available now at www.thebrokersga.com.

Watch for Oscar on LA-area billboards and vehicles, as well as on YouTube. You’ll also hear more about them on Spotify. Make sure you’re appointed with Oscar through Dickerson in case your clients ask.

 
Contact your Dickerson Account Executive for more information about Oscar’s small group plans.

 

EaseCentral

Want to save time and cut down on mistakes during open enrollment? Why not talk with your groups about the benefits of Electronic Enrollment? The best news is that when you submit your business through Dickerson, EaseCentral Electronic Enrollment setup is free.

After enrolling, your clients have a system that they can use all year to track changes and onboard new hires.Watch this 2-minute video to learn more. Then, ask your Account Executive about how you can enroll your next group paper-free and hassle-free.

Industry Events/Professional Development

All Things Compliance (2 Hour CE, #368191)
Orange County:
Monday, July 23, 2018 @ 8:30 am – 11 am
Click here
to register
Los Angeles County:
Tuesday, July 24, 2018 @ 9:30 am – 12 pm
Click here
to register
Inland Empire:
Wednesday, July 25, 2018 @ 8:30 am – 11 am
Click here
to register

Stop by Dickerson’s booth at the following events:

CAHU Health Care Summit
August 7-9, 2018
Hilton San Diego Bayfront
1 Park Blvd.
San Diego, CA 92191
Click here
to register

OC/IE/SD Medicare Summit
August 22 & 23, 2018
45000 Pechanga Pkwy
Temecula, CA 92592
Click here
to register

Anthem Blue Cross Discontinues Service at Community Hospital Long Beach Due to Closure

Anthem Blue Cross announced that Community Hospital Long Beach has closed and discontinued all services, effective July 3, 2018. Letters have been mailed to members who sought services or had a family member receive services in the last 12 months, as well as to physicians with admitting privileges at the hospital.

The hospital in located in the City of Long Beach in Los Angeles County. For a list of alternate hospitals and post-termination care, as well as detailing of how members are affected, please download Anthem’s FAQ here.

 

Blue Shield Announces San Mateo Direct Contract HMO closure

In an effort to lower the cost of health care, Blue Shield will be closing the San Mateo Blue Shield Administered Direct Contract HMO (San Mateo DCHMO) and moving members to alternate IPAs. The alternate IPAs are Brown and Toland Medical Group, Dignity Health Medical Network Sequoia, Hill Physicians San Francisco, Palo Alto Medical Foundation (PAMF), and PAMF Mills Peninsula Division.  This means that all members will be transitioned to an alternate IPA; the last day in the HMO pod will be August 31, 2018.

 

For information on how this affects Blue Shield members, click here.

Trump administration freezes risk adjustment payments

Click here to read the article online.

The Trump administration is halting billions of dollars of payments to insurers under the Affordable Care Act’s risk-adjustment program, a move that further disrupts the insurance market and could lead to more premium increases next year.

Citing conflicting federal court decisions on the program, the CMS said it cannot collect or disburse funds under the risk-adjustment program. All in all, the program was slated to shift $10.4 billion among insurers in 2017, according to the agency.

The permanent program was meant to reduce the incentive for health insurers to cherry-pick healthy members. It shuffles money from plans with healthier-than-average members to those with larger numbers of sicker, higher-cost members. The program is based on a patient’s risk score, which is determined by a person’s demographic information and health condition.

But U.S. District Judge James Browning of New Mexico ruled in February that HHS couldn’t use statewide average premiums to come up with its risk-adjustment formula because the agency wrongly assumed the ACA required the program to be budget-neutral.

“CMS has asked the court to reconsider its ruling, and hopes for a prompt resolution that allows CMS to prevent more adverse impacts on Americans who receive their insurance in the individual and small group markets,” CMS Administrator Seema Verma said in a July 7 statement.

America’s Health Insurance Plans said it was “very discouraged” by the CMS’ decision, which comes as insurers determine their premiums for 2019 and states review those proposals.

“The decision will have serious consequences for millions of consumers who get their coverage through small businesses or buy coverage on their own,” the group said. “It will create more market uncertainty and increase premiums for many health plans—putting a heavier burden on small businesses and consumers, and reducing coverage options. And costs for taxpayers will rise as the federal government spends more on premium subsidies.”

The risk-adjustment program has been a source of frustration for small insurers and ACA co-ops that claim the formula makes their membership bases look healthier than they are. One reason could be that newer insurers have limited information on their members’ health status and claims history. Legacy insurers that have a wealth of patient data may have a leg up on coding. Small health plans also have far less capital than more established insurers to comfortably make large risk-adjustment payments.

The CMS has asked Judge Browning to reconsider his ruling and is awaiting a decision. The agency said it will release additional guidance for insurers on issues related to the risk-adjustment program, including appeals and how this will affect medical loss ratios.

Here are the 16 health care bills proposed after California shelved single-payer

By Angela Hart
ahart@sacbee.com

View as a webpage here. To find out which of these are CAHU priority bills, please click here.

Here is a rundown of the 16 bills proposed by Democratic lawmakers after the Assembly’s special health care hearings concluded. The hearings began following a decision last year by Speaker Anthony Rendon to shelve a controversial single-payer health care bill.

Assembly Bill 2965: Would expand Medi-Cal eligibility to undocumented adults ages 19 to 25. Currently on suspense in the Senate Appropriations Committee. The Legislative Analyst’s Office estimates the expansion would cost an additional $140 million annually from the general fund. Unlikely to advance.

Assembly Bill 3148: Would have required Covered California to offer additional financial assistance to low- and middle-income people purchasing insurance through the exchange. Died in the Assembly Appropriations Committee in May. Assistance would have cost roughly $500 million annually from the general fund, according to an estimate by the University of California, Berkeley Labor Center.

Assembly Bill 2565: Would require Covered California to boost health insurance premium assistance to low- and middle-income people. Held in Assembly Appropriations Committee. Assistance estimated to cost $500 million annually. Unlikely to advance.

Assembly Bill 2416: Attempts to create greater access to care and more competition between health plans in areas with two or fewer plans selling insurance coverage through Covered California. It would require health plans with Medi-Cal contracts in underserved counties to negotiate with Covered California for potential inclusion on the exchange. Held in Assembly Appropriations Committee. Additional staff costs for Covered California of up to $300,000. Unlikely to advance, contents moved to Assembly Bill 2472.

Assembly Bill 2472: Encourages greater competition between plans, and would require Covered California to study creating a public health insurance option to compete with private insurers on the exchange. Decision expected in August. One-time costs in the range of $250,000 for Covered California to contract for the report.

Assembly Bill 2499: Would require insurers to spend a set amount — at least 80 percent — of insurance premium dollars on care instead of administrative costs and profit. Decision expected in mid-August. Additional administrative costs by state Department of Insurance and Department of Managed Health Care.

Assembly Bill 2430: Would let a larger number of low-income seniors, disabled and blind adults qualify for free Medi-Cal. Currently in Senate Appropriations Committee. Total cost for the first year would be $51.4 million, growing to $153.6 million the following year, according to a Senate analysis. Unlikely to advance.

Assembly Bill 2459: Would provide a personal income tax credit for nearly 400,000 low- and moderate-income people who purchase insurance through Covered California, equal to the amount of their health insurance premiums. Moving through policy committees in the Senate but unlikely to advance due to its high price tag. Would cost $500 million in general fund dollars annually, and would likely grow as health care costs continue to rise. It would also cost an estimated $2.2 million per year in administrative costs.

Assembly Bill 2579: Would automatically enroll women and children whose incomes qualify them for food stamps into Medi-Cal, creating a so-called “express lane.” Referred to Senate Appropriations Committee. Would cost the state Department of Health Care Services $400,000 in the first year to begin the program, and result in $200,000 ongoing costs likely paid for with federal health care dollars divvied out to the state.

Assembly Bill 2597: Seeks to increase the number of primary care doctors in the state by boosting state funding for University of California medical training programs. Referred to Senate Appropriations Committee. Cost would be $9.35 million in general fund money for the University of California system. Unlikely to advance.

Assembly Bill 2718: Expands from six months to one year Medi-Cal coverage to low-income individuals or families transitioning out of other financial assistance programs. Annual ongoing costs would be about $6 million, with roughly half coming from the state general fund. Included in budget negotiations but was not funded. Referred to Senate Appropriations Committee. Unlikely to advance.

Assembly Bill 2275: Seeks to further regulate Medi-Cal managed care plans by creating stronger care quality benchmarks. Referred to Senate Appropriations Committee. Annual costs of $3.1 million per year, covered by state and federal funds.

Assembly Bill 2427: Would increase the state’s ability to regulate health plans and penalize them for engaging in anti-competitive business practices by restricting them from Medi-Cal. Referred to Senate Appropriations Committee.

Assembly Bill 2502: Establishes a database to track payments to health care providers and insurers, with a goal of increasing transparency around health care prices. Proposal included in the state budget signed last week by Gov. Jerry Brown with $60 million appropriated this year.

Assembly Bill 2517: Sets California on a potential path toward a form of single-payer health care. Proposal also included in the state budget, with $5 million appropriated this year to provide a “road map” with benchmarks to move California toward a “unified publicly funded health care system,” according to the bill’s authors. System could be publicly funded or a hybrid to include coverage provided by and paid for by employers. Version included in state budget.

Assembly Bill 3087: Would have created a California “Health Care Cost, Quality and Equity Commission” to control in-state health care costs and set payment rates for health plans, hospitals, physicians, doctor groups and other providers. Held by author due to staunch opposition.

Dickerson Update June 29, 2018

Time is flying by and the year is halfway over! Here’s a sneak peek at what Anthem and Blue Shield have coming in 4th quarter, plus some quick regulatory news.

Click here to view as a webpage.

Anthem

Anthem reports that it will have a rate pass, on average, for Q4. For PPO plans, the average rate changes are 0.4% quarterly and – 1.4% annually. For HMO, the quarterly rate change is – 3.1% and annually, it is -3.7%. Click here to quote now.
 
As a reminder, relaxed new business underwriting guidelines continue through 12/15/18 effective dates.
  • 25% participation for groups of 5 + enrolled subscribers
  • 65% participation for groups of 1-4 enrolled subscribers
  • DE9C not required with 6 or more enrolling. Groups with prior coverage must submit prior carrier bill.
  • Valid Waivers: Individual coverage both on and off the Exchange will be accepted as a valid waiver
  • Dual HMO Networks: Groups can select both HMO networks to be offered alongside each other

For more information, click here.

Anthem Blue Cross has renewed its Commercial Hospital Agreement with Valley Children’s Hospital and with St. Agnes Medical Center effective July 1, 2018. Valley Children’s Hospital is in Madera County and St. Agnes Medical Center is in Fresno County.

Once both institutions have been reinstated, Anthem will notify all parties who received a termination letter (members, clients, brokers, agents, and physicians). For more information, please contact your Dickerson Account Executive.

Blue Shield

 
Blue Shield announced a statewide average rate action of 0% for its small business plans in Q4.
  • HMO rates, including Trio, decrease 2.1% in the fourth quarter, annualized for a 1.8% increase in 2018.
  • PPO rates increase 0.7% in the 4th quarter, annualized for a 3.7% increase in 2018.
  • Statewide average rate action for all plans is 3.1% for the year.
4th quarter 2018 average
All plans 0.0% 3.1%
PPO plans 0.7% 3.7%
HMO plans -2.1% 1.8%

Blue Shield Q4 rates will be available at www.thebrokersga.com beginning in early July.
As a reminder, small groups that have terminated their PEO arrangements are not eligible for the “No DE9C” promotion that is currently in place. In addition to standard underwriting requirements based on the number of enrolling employees, Blue Shield also requires of these groups:
  • A copy of the letter sent from the PEO to the group verifying the cancellation of the leasing arrangement
  • A copy of the group’s payroll register

Should payroll not yet be processed, a copy of a payroll register from the PEO that separates the formerly leased employees by business location will be required.

Lastly, Blue Shield will enhance its Employer Connection Plus (EC+) for a more user-friendly experience, including improved site functionality for mobile devices, new features and self-service capabilities for managing group benefits.

The site’s resource page provides the information you need to take advantage of the enhanced capabilities Employer Connection Plus offers, such as:

  • FAQs
  • Broker and Employer access instruction training videos
  • Registration for an online guided tour
  • Recorded webinar sessions
  • Administrator’s Guide
No action is required for now, so stay tuned for future updates. To learn more about this update, click here

Regulatory Update: IRS Announces…

This just in: the IRS has announced the 2019 limits for contributions to health saving accounts and high deductible health plans. For the 2019 calendar year, an HDHP is a health plan with an annual deductible no less than $1,350 for self-only plans and $2,700 for family coverage.

Keep in mind that annual out-of-pocket expenses cannot exceed $6,750 for self-only plans and $13,500 for family coverage. For individuals with self-only coverage under a HDHP, the 2019 annual contribution limit to an HSA is $3,500 and for an individual with family coverage, the HSA contribution limit is $7,000.

No change was announced to the HSA catch-up contribution limit, which remains at $1,000 for individuals that are 55 or older.

More news from the IRS…The ACA affordability percentage for Applicable Large Employers for 2019 has gone from 9.56% to 9.86%. In order for a plan to be “affordable” under the ACA requirements for employers with 50 or more full-time equivalent employees, the employee-only premium for the lowest cost plan offered cannot be more than 9.86% of the employee’s income in 2019.

Industry Events/Professional Development

Pants on Fire – Agent Ethics (2 Hour CE, #366831)

Tuesday, July 10, 2018 @ 9 am – 12 pm
Dickerson Training Room
1918 Riverside Dr.
Los Angeles, CA 90039
Click here
to register

ERISA and Other Compliance Issues (2 Hour CE, #368191)

Orange County: Monday, July 23, 2018 @ 8:30 am – 11 am
Click here
to register
Los Angeles County
: Tuesday, July 24, 2018 @ 9:30 am – 12 pm
Click here
to register
Inland Empire
: Wednesday, July 25, 2018 @ 8:30 am – 11 am
Click here
to register

 

Important Changes Coming to Blue Shield’s Employer Connection Plus

Blue Shield is making updates to its Employer Connection Plus this summer to bring you new features and a friendlier user experience. Click here for more information, including:

  • When the new tools will be introduced
  • Which groups are included
  • Why EC+ is changing
  • What the enhanced features are
  • Where to get training on the new tools

DOL Releases Final Rule Expanding Association Health Plans

Click here to view as a webpage.

The U.S. Department of Labor (DOL) has issued a final rule expanding the opportunity of unrelated employers of all sizes (but particularly small employers) to offer employment-based health insurance through Association Health Plans (AHPs).  Significantly, the final rule applies “large group” coverage rules under the Affordable Care Act (ACA) to qualifying AHPs.

The final rule confirms that AHPs may be formed by employers in the same trade, industry, line or businesses, or profession.  They may also be formed based on a geographic test such as a common state, city, county or same metropolitan area (even if the metropolitan area includes more than one State).

The final rule contains staggered effective dates:

  • All associations (new or existing) may establish a fully insured AHP beginning September 1, 2018.
  • Existing associations that sponsored an AHP on or before the date the final rule was published may establish a self-insured AHP beginning January 1, 2019.
  • All other associations (new or existing) may establish a self-insured AHP beginning April 1, 2019.

We will expand upon these issues in future alerts.  In the meantime, highlights of the final rule are as follows:

  • Existing bona fide associations may continue to rely on prior DOL guidance.  The final rule provides an additional mechanism for AHPs to sponsor a single ERISA-covered group health plan.
  • AHPs may self-insure under the final rule; however, the DOL anticipates that many AHPs will be subject to state benefit mandates.  States retain the authority to adopt minimum benefit standards, including standards similar to those applicable to individual and small group insurance policies under the ACA, for all AHPs.
  • The primary purpose of the association may be to offer health coverage to its members; however, it also must have at least one substantial business purpose unrelated to providing health coverage or other employee benefits. A “substantial business purpose” is considered to exist if the group would be a viable entity in the absence of sponsoring an employee benefit plan.
  • The employer members of an association must control the functions and activities of the association, and the employer members that participate in the group health plan must control the plan. Control must be present both in form and in substance.
  • Whether “control” exists is a facts and circumstances determination.  The DOL considers the following factors to be particularly relevant for this analysis: (1) whether employer members regularly nominate and elect the governing body of the association and the plan; (2) whether employer members have authority to remove a member of the governing body with or without cause; and (3) whether employer members that participate in the plan have the authority and opportunity to approve or veto decisions which relate to the formation, design, amendment, and termination of the plan, for example, material amendments to the plan, including changes in coverage, benefits, and premiums.
  • The AHP must limit enrollment to current employees (and their beneficiaries, such as spouses and children), or former employees of a current employer member who became eligible for coverage when the former employee was an employee of the employer.
  • An AHP may not experience-rate each employer member based on the health status of its employees; however, an AHP may charge different premiums as long as they’re not based on health factors.  For example, employees of participating employers may be charged different premiums based on their industry subsector or occupation (e.g., cashier, stockers, and sales associates) or full-time vs. part-time status.
  • The final rule reduces the requirement for working owners. To be eligible to participate they must work an average of 20 hours per week or 80 hours per month (the proposed rule required an average of 30 hours per week or 120 hours per month).
  • All AHPs are Multiple Employer Welfare Arrangements (MEWAs) and will need to ensure compliance with existing federal regulatory standards governing MEWAs (such as M-1 filings). The Department intends to reexamine existing reporting requirements for AHPs/MEWAs, including the Form M-1 and possibly the Form 5500, and may be asked to propose class or individual prohibited transaction exemptions for AHPs that want to use affiliates to serve as their administrative service providers or act as issuers providing benefits under the AHP.
  • States can continue to regulate AHPs.
  • AHPs are subject to the disclosure requirements of Title I of ERISA (e.g., summary plan descriptions, summary of material modifications, etc.) and Summary of Benefits and Coverage (SBC) requirements.
  • The Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), which applies to employers with more than 50 employees on business days during the preceding calendar year, would apply to an AHP so long as the number of employees employed in the aggregate during the preceding calendar year by the employer members of the bona fide group or association.
  • The DOL anticipates issuing future guidance on the application of COBRA to AHPs.
  • The rule does not address the liability of the respective parties to the AHP for violations of the nondiscrimination provisions in the rule, general ERISA reporting and disclosure requirements and fiduciary rules, Code section 4980H (employer mandate) and the related Code sections 6055 and 6056 reporting requirements, Form W-2 reporting, COBRA compliance, and “all of the other responsibilities that come with the maintenance of a single large employer plan.” These Code provisions are under the jurisdiction of the IRS and Treasury and the rule refers stakeholders to the relevant Code sections and guidance thereunder.

Next Steps

The release of final regulations expanding the availability of AHPs will come as welcome relief to small employers, who have been subject to strict insurance mandates and market reforms under the Affordable Care Act.  The final rule is intended to level the playing field and allows small employers to band together by common geography or industry to purchase “large group” insurance policies, which are subject to fewer ACA mandates and have greater flexibility in plan design than small group plans, which generally must offer coverage in all ten essential health benefit categories. However, States will continue to be able to regulate AHPs, so it remains to be seen whether some of the flexibility gained under the final rule will be curtailed by the adoption of minimum benefit standards by States.

The rule also enables AHPs to self-insure, which provides an additional avenue for cost-savings by participating employers.  While the impact on the ACA Marketplaces and the individual and group insurance markets is unclear and likely will not be felt immediately, opponents of the rule have raised concerns ranging from destabilization of the individual and small group markets (due to AHPs being marketed toward younger, healthier individuals) to consumer protection issues, including insolvency and fraud.

Employers should work closely with qualified ERISA counsel and their trusted advisors when evaluating whether to join an AHP and to ensure that compliance obligations are being met.

___________________________________________________________________________________________________________

About the Author. This alert was prepared by Marathas Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act.  Contact Peter Marathas or Stacy Barrow at pmarathas@marbarlaw.com or sbarrow@marbarlaw.com.

The information provided in this alert is not, is not intended to be, and shall not be construed to be, either the provision of legal advice or an offer to provide legal services, nor does it necessarily reflect the opinions of the agency, our lawyers or our clients.  This is not legal advice.  No client-lawyer relationship between you and our lawyers is or may be created by your use of this information.  Rather, the content is intended as a general overview of the subject matter covered.  This agency and Marathas Barrow Weatherhead Lent LLP are not obligated to provide updates on the information presented herein.  Those reading this alert are encouraged to seek direct counsel on legal questions. © 2018 Marathas Barrow Weatherhead Lent LLP.  All Rights Reserved.

Insurance Commissioner Issues Statement on Federal Association Health Plan Rule

By Dave Jones, California Insurance Commissioner.

Insurance Commissioner Jones issues statement on federal Association Health Plan rule

SACRAMENTO, Calif. — “Today, the Trump Administration issued its final rule regarding Association Health Plans, described in the rule as a type of Multiple Employer Welfare Arrangement (MEWA), promoting these plans as a path for groups of businesses or organizations to obtain health insurance coverage. Some MEWAS have had a troubling history in California, including cases of MEWA fiscal insolvency, inability to pay consumer claims, and allegations of fraud, so California law prohibits the formation of any new MEWAS. The final rule recognizes continued state regulation of MEWAS; however, outside California, the Trump Administration’s final rule threatens the continued existence of comprehensive health insurance coverage, as those who are sick may no longer be provided coverage that meets their health care needs or may obtain coverage through an arrangement that may later fail when needed most.”