On behalf of our member companies that provide more than 1 million jobs in the state and make the New Jersey Business & Industry Association the largest statewide business association in the country, we are writing to respectfully OPPOSE Assembly Bill 389 (Benson; Mukherji) / Senate Bill 2649 (Greenstein; Cruz-Perez). These bills require health insurance coverage for certain amino acid-based formulas.
NJBIA is concerned that this measure creates a new health benefits coverage mandate and has not been reviewed by the Mandated Health Benefits Advisory Commission prior to being heard in committee. To create an objective assessment of the impact this health insurance coverage mandate could have on the cost of purchasing healthcare benefits, the Commission is charged with providing the Legislature with independent documentation defining the social and financial impact and medical effectiveness of proposed mandated health benefits legislation.
NJBIA is also concerned that if enacted, this bill will trigger the ACA requirement that the state defray the cost of any new mandate that exceeds the Essential Health Benefits (EHBs) designated by the state as benefits that must be covered under plans sold in the commercial market and ACA marketplace. New Jersey included all the mandated benefits that had been enacted when it determined the state’s EHBs. This is why a cost analysis and review by the Commission is very important because the cost of this mandate would impact the state budget.
The Association places a strong and consistent focus on the quality and affordability of health insurance in New Jersey. The cost of providing health coverage to employees is one of the most significant challenges facing employers today. It is consistently ranked the number one concern facing our members in our annual NJBIA Business Outlook Survey.
The role of the Commission is particularly important considering that employers continue to cope with rising costs for healthcare coverage. In 2017, the average single premium increased 4% and the average family premium increased 3%.
The cost of health insurance premiums reached $7,663 for single HMO coverage and $21,911 for family coverage in the Northeast, according to the Kaiser Family Foundation (Kaiser) and the Health Research & Educational Trust (HRET) annual survey. The national average for all plans is $6,690 for single coverage and $18,764 for family coverage.
According to the most recent NJBIA Health Benefits Survey, the average premium paid in New Jersey for single employee coverage is $7,044 and $17,580 for family coverage.
With the cost of health coverage steadily climbing and coverage continually eroding, it is crucial that the impact of all coverage mandates be carefully evaluated. It is unclear what impact this mandate would have on the cost of health insurance.
For these reasons, we respectfully ask that this legislation be evaluated by the Mandated Health Benefits Commission.
Thank you for your consideration of our comments.