MEMORANDUM IN OPPOSITION

Date: May 2010

Bill: A6647-A (Carrozza)
Act to amend the insurance law and public health laws by requiring insurers to provide certificate holders with at least thirty days prior written notice of termination of group health insurance coverage.

The Employer Alliance for Affordable Health Care is a grassroots coalition of more than 3,000 sole proprietors and small and medium-sized business owners who represent more than 150,000 working New Yorkers. Our members believe that everyone should have access to basic, affordable health insurance. We oppose health insurance mandates that increase premium costs and decrease accessibility of basic, affordable health insurance. This bill seeks to amend existing law by requiring written notice to consumers upon termination of group health insurance.

WE OPPOSE THIS LEGISLATION FOR THE FOLLOWING REASONS:

• Health care costs are among the greatest concern of most small business owners, according to an annual survey conducted by the National Federation of Independent Business. While the intention of this regulation is to protect consumers, the ultimate impact could realistically be increased business costs passed on by carriers through additional fees and assessments. Furthermore, this bill will unduly penalize small businesses that forced to cancel their policies as a result of high costs by assessing the additional expense of notification. As small businesses struggle to absorb annual double-digit premium increases, the best course of action that could taken by New York State to protect consumers would be “do no harm” in terms of any types of any new fees, assessments or regulations such as this which could impact premiums.
• The face of health insurance is changing in light of current federal reform. Rather than creating new regulations and adding further confusion to an already complex problem, the New York Legislature should allow the federal government to take the lead, adopting a “wait and see” attitude to determine whether this type of regulation is being addressed elsewhere.

For these reasons, the Employer Alliance for Affordable Health Care asks you to oppose A6647-A.

The Employer Alliance for Affordable Health Care is a coalition of more than 3,400 employers and individuals from across New York, representing more than 200,000 working New Yorkers, committed to preserving quality affordable health care.