Division of Insurance Releases First Annual Report on Healthcare Sharing Plans and Arrangements Operating in the State

The Colorado Division of Insurance has released its first annual report on healthcare sharing plans and arrangements (HCSAs) operating in the state, calling it just “the first step in finding out more about HCSAs and how they work” so that the Division “can help Colorado consumers to know what they are getting, and, more importantly, what they aren’t getting, when they look at HCSAs.”

The product of legislation passed last year in response to consumer complaints and other concerns about these programs, which generally charge membership fees resembling health insurance premiums but rely principally upon charity care, consumer support organizations, and the voluntary goodwill of other program members to cover medical expenses. Many HCSAs also operate with a religious orientation and often exclude benefits such as contraception coverage, mental health services, alcohol use disorder treatments, ADHD treatments, prescription drugs for chronic conditions, comprehensive reproductive health coverage, abortion and pre-existing conditions.

Issues like these have resulted in some HCSA members being left “stuck with [medical bills] for thousands of dollars,” demonstrating that “people are clearly not getting the full story from the companies when they sign up for HCSAs,” according to the Colorado Insurance Commissioner Michael Conway.

The legislation required HCSAs operating in Colorado to report 2021 membership (including employer groups), financial, marketing efforts, producer and other related data to the state, but full compliance was spotty. In the end, 16 HCSAs with a total combined membership of 67,876 Coloradans (five of which included employer groups) submitted reporting data to the state, though all 16 reports were deemed ultimately incomplete.

14 of the 16 HCSAs submitted financial data, reporting a combined total dollar amount of costs or services that were submitted for sharing of $361,782,968.53, compared to $97,393,551.95 in total fees, dues, shares, contributions, and other payments collected from Colorado members in 2021, which equals 26.7% of members’ healthcare costs.

After adjusting those amounts for duplicate charges, ineligible charges based on sharing guidelines, discounts negotiated on their members' behalf, and the members’ agreed upon portions of medical bills, $131,984,548.13 of members’ total 2021 healthcare costs qualified for sharing, resulting in an adjusted figure of 74% of total eligible share requests covered.

At least seven HCSAs reported working with a total of 862 producers to enroll 4637 members or 35.2% of the enrollment of those seven HCSAs. However, HCSAs are not required to report the name, business, or license number of individual producers, so that 862 count likely includes double counting.

Because the data collected was incomplete, the report itself is not as comprehensive as the Division would prefer, and efforts are underway to obtain complete 2021 data by June 2023 and 2022 data by early fall of 2023.

Colorado Division of Insurance First Annual Report »