CCIIO Guidance on Third Party Payment of Premiums for QHPs

The Center for Consumer Information and Insurance Oversight (CCIIO) has issued new guidance addressing the question of whether third party payors are permitted to make premium payments to insurers on behalf of individuals enrolled in qualified health plans (QHPs).

The guidance states: “The Department of Health and Human Services (HHS) has broad authority to regulate the Federal and State Marketplaces (e.g., section 1321(a) of the Affordable Care Act). It has been suggested that hospitals, other healthcare providers, and other commercial entities may be considering supporting premium payments and cost-sharing obligations with respect to qualified health plans purchased by patients in the Marketplaces. HHS has significant concerns with this practice because it could skew the insurance risk pool and create an unlevel field in the Marketplaces. HHS discourages this practice and encourages issuers to reject such third party payments. HHS intends to monitor this practice and to take appropriate action, if necessary.”