Attachment R - Public Comment from the SIIA

January 8, 2013
Doris Lefkowitz
AHRQ Reports Clearance Officer
Agency for Healthcare Research and Quality
540 Gaither Road
Rockville, MD 20850
Dear Ms. Lefkowitiz:
Re: “Medical Expenditure Panel Survey—Insurance Component.” – Proposed Additions
Please accept the following comments on the above referenced Survey. The Self-Insurance Institute of
America, Inc. (SIIA) is a national trade association representing self-insured employers and their business
partners, including stop-loss insurance carriers.
Specifically, we wish to comment on the proposed additional question – “For self-insured plans that
purchases stop-loss insurance, what is the specific stop-loss coverage amount per employee?” It is our
view that the manner of which the question will create unnecessary confusion among respondents.
Regardless of the attachment point level, a stop-loss insurer never makes a payment to a provider on
behalf of an individual, as the employer/plan-sponsor is liable for full payment of every claim against the
plan. The stop-loss insurer simply reimburses the plan for claims paid above the contractually agreed
upon attachment point levels. Moreover, a stop-loss insurer never provides health coverage to an
individual.
For these reasons we believe the wording of the additional question related to stop-loss insurance
should be changed to read: “What is the specific stop-loss deductible on the covered participants of the
plan?” This change will allow for a more accurate collection of data, which will certainly benefit your
Agency’s mission.
Please contact SIIA Government Relations Director Jay Fahrer at 202-463-8161 or [email protected]
should you have any questions regarding these comments.
Thank you for your consideration.
Respectfully,
Mike Ferguson
Chief Operating Officer