We write to urge New York State to maintain its current course to expand the small group market to include groups with members between 50 and 100 and retain the State’s current prohibition on stop-loss coverage for the small group market.
We understand that the State is considering a proposal that would permit group health plans in the 50-100 employee market to maintain their existing plans after January 1, 2016. As you know, HCFANY has long advocated for a merged market of individuals, small employers and larger employers up to 100 employees in a single risk pool, as such a merger would most equitably distribute the risk of high health expenses among individual purchasers, sole proprietors, and small and medium sized businesses. The health premiums New York consumers and employers pay should not be based on an artificial division of the market into segments based on employment status or the size of the employer.

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• HCFANY letter on expansion of small group to 100 final