Hospital Sponsorship of Exchange Premiums

October 1, 2014

To:  Hospital CEOs, CFOs, and Legal Counsel

From:  Barbara Gorham, WSHA Policy Director, Access
barbarag@wsha.org; 206-216-2512
 
Subject:  Hospital Sponsorship of Exchange Premiums
 
Purpose
The purpose of this bulletin is to inform you about a potential opportunity for hospitals, working with foundations, to help low-income patients pay the premiums for their Exchange-purchased health plan. It is also intended to give you guidance from the American Hospital Association regarding the legality of sponsoring premiums. 
 
Applicability/Scope
Any hospital interested in sponsoring Exchange premiums.    
 
Overview
The federal government has concluded that private, not-for-profit foundations may sponsor Exchange premiums as long as:  1) the payments are made on behalf of Exchange enrollees who satisfy defined financial criteria; 2) eligibility does not take into consideration an applicant’s health status; and 3) the premiums and any cost-sharing arrangements are provided for an entire year. The AHA has summarized this advice in an advisory linked below.    
 
Project Access Northwest is a Seattle-based nonprofit organization that collaborates with health care providers to provide medical and dental care for individuals with limited access. In 2014, Project Access Northwest created a pilot Exchange premium sponsorship program that it believes meets federal legal requirements. The program serves individuals making 200% or less of the Federal Poverty Level. During the first year of this program, Project Access Northwest has helped over a hundred individuals pay their Exchange premiums. The funding for the program has come from three Seattle-area hospitals. Project Access Northwest would like to expand their program to other interested hospitals.
 
Next Steps
Contact Project Access Northwest if your hospital would like to participate in their program.  Have your legal counsel review carefully federal legal requirements regarding hospital premium sponsorship before participating in any premium sponsorship program.  
 
Background and References
Click here for the AHA Legal Advisory regarding payments from foundations to Qualified Health Plans.
 
Contact Project Access Northwest’s Executive Director Sallie Neillie for more information about their premium sponsorship program.  Sallie can be reached at 206-496-1590 or sallien@projectaccessnw.org.

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