Letter to Wisconsin Insurance Commissioner on Low Out of Pocket Health Plans

July 8th, 2016

Theodore Nickel

Office of the Commissioner of Insurance
125 South Webster Street
Madison, Wisconsin 53703-3474

Dear Commissioner Nickel:

The undersigned organizations ask you to urge all insurers proposing to sell individual health coverage on the 2017 Marketplace to offer at least one Low Out-Of-Pocket (“Standardized”) health plan option. As you know, insurance companies have until July 22 to submit plan designs to your office.(2) An analysis of the 2016 individual Silver qualified health plans in Wisconsin shows that the average medical deductible for qualified health plans across the state is $3,347 and the average prescription drug deductible is $1,202. Nearly one in five people who bought their own insurance last year didn’t fill a prescription because they couldn’t afford it. Clearly, the higher the deductible a consumer has, the less likely they are to get needed medical treatment that would reduce or eliminate high cost crisis services.(4)


In February, the Center for Medicare & Medicaid Services proposed a “Low Out-Of-Pocket” or “Standardized” plan design that they hope Marketplace insurers will offer to all health care consumers in 2017.(1) The benefits of Low Out-Of-Pocket health plans are clear. In addition to a more consumer friendly benefit design, Low Out-Of-Pocket health plans prohibit requiring a deductible for many necessary medical services such as doctor visits or for prescription drugs.(3) Furthermore, the US Department of Health and Human Services has suggested that Low Out-Of-Pocket health plans are likely to be featured with priority placement on Healthcare.gov.(5)

Because the decision to offer Low Out-Of-Pocket (“Standardized”) health plans is optional for insurance companies, we request that you encourage insurers in your communication before the July 22 deadline to exercise that option and submit a 2017 Marketplace plan that is truly affordable for all Wisconsin residents.(2)  Early research indicates that premiums have not had to noticeably rise for these Low Out-Of-Pocket health plans,(3) and preliminary discussions with some Wisconsin insurers suggest that some companies will introduce a Low Out-Of-Pocket health option. We simply ask that you encourage every insurer to do the same.

In summary, if even a few insurance companies offer Low Out-Of-Pocket health plans in 2017, Wisconsin consumers could save tens to hundreds of millions per year in out-of-pocket costs. Further, as consumers are given freer access to timely care by reducing affordability barriers, that increased access will reduce the prevalence of urgent, expensive, and emergency treatments for what are preventable and manageable conditions.


  • AFSCME Council 32
  • American College of Physicians, Wisconsin Chapter
  • Citizen Action of Wisconsin
  • National Alliance on Mental Illness (NAMI) Wisconsin
  • Wisconsin AFL-CIO
  • Wisconsin Council of Churches
  • Wisconsin Council on Children and Families
  • Wisconsin Faith Voices for Justice
  • Wisconsin Federation of Nurses & Health Professionals

1 - Centers for Medicare & Medicaid Services (February 29, 2016) "Final HHS Notice of Benefit and Payment Parameters for 2017” https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2016-fact-Sheets-items/2016-02-29.html

2 - Wisconsin Office of the Commissioner of Insurance (March 28, 2016) “Comprehensive Health Form Filing Requirements Individual and Small Group Markets” http://oci.wi.gov/ociforms/comphealth-formfilings.htm

3 - Families USA, “Federal Standardized Health Insurance Plans Could Improve Access to Care without Raising Premiums” (May, 2016) http://familiesusa.org/sites/default/files/product_documents/ACA_Millliman%20Report_online.pdf

4 - HealthAffairs, (February 4, 2016) “Health Policy Brief, High-Deductible Health Plants” http://healthaffairs.org/healthpolicybriefs/brief_pdfs/healthpolicybrief_152.pdf

5 - Centers for Medicare & Medicaid Services (April 29, 2016) "Simplifying Choices in the Marketplace-Simple Choice Plans and Quality Star Ratings” https://blog.cms.gov/2016/04/29/simplifying-choices-in-the-marketplace-simple-choice-plans-and-quality-star-ratings/

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