Has anyone thought about whether the regulations issued for the pre-existing condition insurance plan program (i.e., the high risk pool program under PPACA) prohibit employers from offering cash to employees to waive employer-sponsored health coverage? I am curious about whether these cash incentives could be considered insurer dumping under 45 CFR 152.28. How are you handling this? Are you discontinuing the cash incentives? Thanks.

Are you saying that the employer was/is offering cash to employees, with pre-existing conditions, to opt out of health insurance coverage?

Not specifically to employees with pre-existing conditions, but to all employees. For example, an employer might offer employees $100 per month cash to decline health coverage, perhaps contingent on the employee certifying that he or she has coverage available through a spouse. But what if instead the employee ends up enrolling in the high risk pool. It now looks like he received a financial incentive to leave employer group coverage and sign up for the pool, which is a problem. Many employers offer these cash incentives for employees to decline coverage. I am just wondering whether anyone thinks that these high risk regulations should make us question continuing this practice.