Providing for Congressional Disapproval Under Chapter 8 of Title United States Code, of the Rule Submitted By the Secretary of the Treasury, Secretary of Labor, and Secretary of Health and Human Services Relating to ``Short-Term, Limited Duration Insurance''

Floor Speech

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Ms. BALDWIN. 627, S.J. Res. 63.

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Ms. BALDWIN. Mr. President, just over a year ago in this Chamber, three brave Republican colleagues--Senator John McCain, Senator Susan Collins, and Senator Lisa Murkowski--joined all Democrats in voting against healthcare repeal legislation. They listened to the families of their States.

I, too, voted against that repeal legislation because the people of Wisconsin did not send me to Washington to take away their healthcare. When congressional Republicans tried to pass repeal plans that would allow insurance companies to charge more for preexisting conditions, families across our country fought back.

When the Republican majority tried to charge older Americans an age tax and make people pay more for less care, people let their voices be heard and sent a loud message to Washington: Protect our care. They sent us all a clear message that they want us to work across party lines to protect the healthcare guarantees they depend on and to stand up for those with preexisting health conditions. Yet defeating the legislative efforts that would have made things worse for families didn't end the threat to the American people.

The Trump administration has been trying to do what congressional Republicans couldn't. They have been sabotaging our healthcare system and rewriting the rules on guaranteed health protections and access to affordable care that millions of Americans have today. This sabotage has created instability in the healthcare market, contributing to widespread premium spikes in 2018.

This administration ended the critical cost-sharing reduction payments that made healthcare more affordable for almost 90,000 Wisconsinites. The Trump administration again slashed funding for outreach efforts to help people sign up for healthcare.

Trusted navigator programs like those in Wisconsin have had their funding cut by nearly 90 percent in the past 2 years. This will mean fewer people in rural Wisconsin will receive the support they need to obtain affordable coverage this year.

It doesn't stop there. The Trump administration has even joined Wisconsin's Governor and Wisconsin's attorney general and other States in going to court to support a lawsuit that would take away guaranteed protections for people with preexisting conditions. If they succeed, insurance companies will again be able to deny coverage or charge higher premiums for the more than 130 million Americans with a preexisting health condition. In fact, if the Affordable Care Act's protections for people with preexisting conditions are struck down in court, Wisconsin is among the States that has the most to lose.

According to the Kaiser Family Foundation, one out of every four Wisconsinites has some sort of preexisting health condition, and they simply cannot afford to have the healthcare they depend on threatened with higher costs or coverage denials.

The Trump administration has expanded junk insurance plans. These plans are cheap for a reason; they do not have to provide essential health benefits like hospitalization, prescription drugs, and maternity care.

According to the fine print of one of the plans sold in several States, including my home State of Wisconsin--marketed by the Golden Rule Company--the plan doesn't even have to cover hospital care on a Friday or Saturday. It will be just your bad luck if you happen to get sick and need healthcare on the weekend. The very first exclusion states that it provides no benefits for a preexisting health condition. The fine print also notes if you are pregnant, that will be considered a preexisting health condition.

These junk insurance plans can deny healthcare coverage to people with preexisting conditions when they need it the most, and that is why I am leading this effort in the U.S. Senate to take action and stop this sabotage.

This is personal to me. When I was 9 years old, I got sick. I was really sick. I was in the hospital for 3 months. I eventually recovered. When it came to health insurance, it was as if I had some sort of scarlet letter. My grandparents, who raised me, couldn't find a policy at any price that would cover me--not from any insurer--all because I was a childhood branded with those words: ``preexisting condition.''

This is also personal for Chelsey from Seymour, WI, whose daughter was born with a congenital heart defect. Right now, Zoe is guaranteed access to coverage without being denied or charged more because of her preexisting condition.

Chelsey wrote me during that debate last year: ``I'm pleading to you as a mother to fight for the kids in Wisconsin with pre-existing conditions that are counting on you to protect that right.''

No parent or grandparent should have to lie awake at night wondering if the healthcare they have today for themselves and their families will be there tomorrow. With the expansion of these junk plans, that fear could become a new reality for far too many families as healthy people leave the market, increasing premiums for everyone.

Children like Zoe may not be able to find any plan that her parents can afford or that will cover the care she needs. No family should be forced to choose between helping a loved one get better or going bankrupt.

Before the Affordable Care Act, too many families had to make that choice. Before the healthcare law, I heard from Sue from Beloit, WI. Sue's husband was diagnosed with lung cancer. They quickly found out their insurance plan had a $13,000 limit on radiation and chemotherapy. That covered about one round of chemotherapy. When they needed to continue treatment, Sue and her family used all of their savings, and then they maxed out all of their credit cards. When they were facing insurmountable credit card debt, she told me: ``I had no choice but to file bankruptcy.'' Sue's husband later died.

We can't go back to the days when insurance companies wrote the rules, just as we cannot allow the Trump administration to rewrite the rules on guaranteed healthcare protections that millions of Americans depend on.

More than 20 of the leading healthcare organizations in America, representing our Nation's physicians, patients, medical students, and other health experts, are supporting this resolution to overturn the Trump administration's expansion of junk insurance plans. They are doing so because these junk plans will reduce access to quality coverage for millions and increase costs.

These junk plans will charge people more for coverage based on their preexisting conditions or deny them coverage outright. These junk plans will leave cancer patients and survivors with higher premiums and fewer insurance options. These junk plans will force premium increases on older Americans.

I have heard my colleagues on the other side of the aisle say that they are committed to protecting people with preexisting conditions. Now is your chance to prove it. Anyone who says they support coverage for people with preexisting conditions should support this resolution to overturn the Trump administration's expansion of these junk insurance plans.

This is an opportunity for Democrats and Republicans to come together to protect people's access to quality, affordable healthcare when they need it the most. Let us join in seizing the opportunity to do what is right by the American people.

I yield.

Dear Speaker Ryan, Leader McConnell, Leader McCarthy, Leader Schumer and Leader Pelosi: Our 113 organizations represent millions of people with serious, acute, and chronic diseases and disabilities, as well as their caregivers. These individuals, and all Americans, need access to comprehensive, affordable health coverage in order to meet their medical needs.

We write to express our concerns about the impact the proposed rule regarding short-term limited duration plans (STLDs) (CMS-9924-P) will have both on the health insurance marketplaces and the individuals we represent. While short term plans can offer less expensive coverage, they are not required to adhere to important standards, including the ten essential health benefit categories, guaranteed issue, out- of-pocket maximums, age-rating protections, and many other critical consumer protections These policies are also allowed to charge much higher premiums, deny coverage altogether for consumers who cannot meet medical underwriting standards, and impose lifetime and annual limits on services. If the proposed rule put forward by the Administration is finalized in its current form, it will limit access to quality and affordable health insurance coverage for all Americans, and disproportionately harm individuals with pre-existing conditions and people with disabilities.

Expanding access to these policies will likely cause premiums in the individual insurance marketplace to increase dramatically, as younger and healthier individuals choose to enroll in cheap short-term plans. Allowing STLDs to proliferate would force individuals, including those with serious or chronic diseases and disabilities, into a smaller, sicker market to obtain the coverage they need to manage their health. Premiums for comprehensive plans that meet federal standards would likely skyrocket, and plans would likely exit the market. This will make insurance either unavailable or unaffordable for those who rely on the marketplace to get coverage

Our organizations are dedicated to identifying and promoting improvements to our health insurance markets that control costs, stabilize the market, and positively impact coverage and care for millions of Americans. Expanding access to STLDs will move us away from--not towards--achieving these goals. As advocates for our communities, we implore you to protect patients and consumers, including individuals with pre-existing conditions and persons with disabilities, by asking the Administration to withdraw this proposed rule until it adequately protects patients and consumers, as well as any rules that do not increase stability, improve affordability, and secure access to quality coverage in our insurance markets. Sincerely,

AARP, Adrenal Insufficiency United, Adult Congenital Heart Association, Adult Polyglucasan Body Disease Research Foundation, Advocacy & Awareness for Immune Disorders Association (AAIDA), Alliance for Aging Research, Alpha-1 Foundation, American Association of People with Disabilities, American Association on Health & Disability, American Cancer Society Cancer Action Network, American Diabetes Association, American Heart Association, American Kidney Fund, American Liver Foundation, American Lung Association, American Multiple Endocrine Neoplasia Support, American Physical Therapy Association, American Therapeutic Recreation Association, Amyloidosis Support Groups.

Arthritis Foundation, Association of Oncology Social Work, Autism Society, Autism Speaks, Autistic Self Advocacy Network, Bazelon Center for Mental Health Law, Benign Essential Blepharospasm Research Foundation, Brain Injury Association of America, CancerCare, Caregiver Action Network, Celiac Disease Foundation, Children's PKU Network, Consortium of MS Centers, Crohn's & Colitis Foundation, Cutaneous Lymphoma Foundation, Cystic Fibrosis Foundation, Disability Rights Legal Center, Dystonia Advocacy Network, Dystonia Medical Research Foundation, Easterseals.

Epilepsy Foundation, Family Voices, Fibrolamellar Cancer Foundation, Fight Colorectal Cancer, FORCE: Facing Our Risk of Cancer Empowered, GBS/CIDP Foundation International, Global Colon Cancer Alliance, Hemophilia Federation of America, Hyper IgM Foundation, Immune Deficiency Foundation, Indian Organization for Rare Diseases, International Myeloma Foundation, International Pemphigus and Pemphigoid Foundation, International Waldenstrom's, Macroglobulinemia Foundation, Interstitial Cystitis Association, Jack McGovern Coats' Disease Foundation, Justice in Aging, LAL Solace, Leukemia & Lymphoma Society.

Lung Transplant Foundation, Lupus Foundation of America, Lutheran Services in America, Lymphangiomatosis & Gorham's Disease Alliance, Lymphatic Education & Research Network, M- CM Network, Malecare Cancer Support, March of Dimes, Mended Little Hearts, Mental Health America, METAvivor, Muscular Dystrophy Association, National Alliance on Mental Illness, National Alopecia Areata Foundation, National Association for Hearing and Speech Action, National Association of Councils on Developmental Disabilities, National Association of State Head Injury Administrators, National Comprehensive Cancer Network, National Consumers League.

National Eosinophilia Myalgia Syndrome Network, National Health Council, National Hemophilia Foundation, National LGBT Cancer Project, National Multiple Sclerosis Society, National Organization for Rare Disorders (NORD), National Patient Advocate Foundation, National PKU Alliance, Inc., National Spasmodic Dysphonia Association, NBIA Disorders Association, NephCure Kidney International, Oncology Nursing Society, Paralyzed Veterans of America, Parent Project Muscular Dystrophy (PPMD), PKD Foundation, Platelet Disorder Support Association, Prevent Cancer Foundation, PRP (Pityriasis Rubra Pilaris) Alliance, Pulmonary Hypertension Association, Rare and Undiagnosed Network (RUN).

Restless Legs Syndrome Foundation, Scleroderma Foundation, Susan G. Komen, Tarlov Cyst Disease Foundation, TASH, The American Liver Foundation, The APS Type 1 Foundation, Inc., The Desmoid Tumor Research Foundation, The Global Foundation for Peroxisomal Disorders, The Guthy-Jackson Charitable Foundation, The Lymphatic Malformation Institute, The Marfan Foundation, United Ostomy Associations of America, US Hereditary Angioedema Association, Vasculitis Foundation, Worldwide Syringomyelia & Chiari Task Force. ____ National Association of Insurance Commissioners & The Center for Insurance Policy and Research, Washington, DC, April 23, 2018. Re Short-Term, Limited-Duration Insurance CMS-9924-P. Centers for Medicare & Medicaid Services, Department of

Health and Human Services, Attention: CMS-9924-P, Baltimore, MD.

To Whom It May Concern: Thank you for the opportunity to comment on the proposed regulations on Short-Term, Limited Duration Insurance published in the Federal Register on February 21, 2018. These comments are submitted on behalf of the members of the National Association of Insurance Commissioners (NAIC), which represents the chief insurance regulators in the 50 states, the District of Columbia, and the 5 United States territories.

As state insurance regulators we have the primary responsibility of regulating our insurance markets and ensuring consumers are protected and the markets are competitive. As we stated in our comments on the current short-term, limited duration regulation, ``Federal interference can, and often does, have unintended consequences and may not be effective in addressing the underlying issues.'' We argued that the arbitrary 3-month limitation set by the Federal government could harm some consumers and limit choices. Returning the Federal definition to ``less than 12 months,'' as proposed, is consistent not only with longstanding federal law but also with how this term has been long defined by most states.

In the analysis of Economic Impact and Paperwork Burden related to federalism, the proposed rule states:

Federal officials have discussed the issue of the term length of short-term, limited duration insurance with State regulatory officials. This proposed rule has no federalism implications to the extent that current State law requirements for short-term, limited duration insurance are the same as or more restrictive than the Federal standard proposed in this proposed rule. States may continue to apply such State law requirements.

Consistent with this statement, any further requirements, including but not limited to restrictions related to the sale, design, rating or duration of these plans, must be left to the States, which have the primary authority under our federal system to regulate the business of insurance, so that they can address the unique conditions and needs of their respective insurance markets. It is critical that state regulators maintain the flexibility to determine whether, and under what conditions, these plans are appropriate for their state. We urge continued state flexibility on this issue.

We also agree that educating consumers and ensuring that they are aware of the limitations of these plans is paramount. Some of these plans may provide significantly less coverage and consumer protections than comprehensive plans. We supported the disclosure requirements in the current regulations and support the expansions in this proposed rule.

States have received several consumer complaints about confusion and misinformation regarding their short-term or excepted benefit plans. Because of the real risk that consumers may confuse short-term policies with comprehensive health insurance that complies with the Affordable Care Act (ACA), it is important that they be made aware of any limitations to these policies during the sales process. We are pleased that the proposed rule retains these important disclosure requirements and adds valuable additional disclosures.

As drafted, this rulemaking does not address the impact of Section 1557 of the ACA on the issuance of short-term, limited duration plans. Specifically, it is unclear whether or not these plans will be considered to be a ``health program or activity'' under 45 C.F.R. Sec. 92.4 This distinction is critical.

If these plans are not exempt from the definition of ``health plan or activity,'' the implication would be that carriers could not offer these plans and also participate on the Marketplace, Medicare, or Medicaid. In many states throughout the country, carriers are deciding whether or not to participate in the ACA-compliant marketplace, and if clarifying language is not included carriers will be forced to choose either to offer short-term, limited duration plans or participate in the Exchange. We would ask for clarification on this issue, and specifically advise that CMS include language in the proposed definition of ``short-term, limited duration insurance'' providing that such insurance is ``not a health program or activity as defined in 45 C.F.R. Sec. 92.4.''

As to the issue of renewability, the members of the NAIC concur that any decision over whether and when these plans should be renewable should be left up to the States, not dictated by the Federal government.

Finally, states are concerned about the timing of this rule, and some states may want to modify existing laws and regulations to protect consumers and state markets. Therefore, we recommend that the final regulation allow states, if they so choose, to begin enforcing the new rules in 2020, thus giving them time to review their rules and seek statutory or regulatory changes to facilitate a smooth transition.

Thank you for this opportunity to comment. We are available to discuss these or other issues as the Short-Term, Limited Duration Proposed Rule is finalized. Sincerely, Julie Mix McPeak,

NAIC President, Commissioner, Tennessee Department of Commerce & Insurance. Raymond G. Farmer,

NAIC Vice President, Director, South Carolina Department of Insurance. Eric A. Cioppa,

NAIC President-Elect, Superintendent, Maine Bureau of Insurance. Gordon I. Ito,

NAIC Secretary-Treasurer, Commissioner, Insurance Division, Hawaii Department of Commerce and Consumer Affairs. ____ UnitedHealthcare, Golden Rule Insurance Company Short Term Medical Plans

STATES: AZ, FL, IA, IL, IN, MI, MS, NE, PA, TN, TX, WI, WV

This coverage is not required to comply with certain federal market requirements for health insurance, principally those contained in the Affordable Care Act. Be sure to check your certificate carefully to make sure you are aware of any exclusions or limitations regarding coverage of preexisting conditions or health benefits (such as hospitalization, emergency services, maternity care, preventive care, prescription drugs, and mental health and substance use disorder services). Your certificate might also have lifetime and/or annual dollar limits on health benefits. If this coverage expires or you lose eligibility for this coverage, you might have to wait until an open enrollment period to get other health insurance coverage. Also, this coverage is not ``minimum essential coverage.'' If you don't have minimum essential coverage for any month in 2018, you may have to make a payment when you file your tax return unless you qualify for an exemption from the requirement that you have health coverage for that month. What's Not Covered (all plans)

This is only a general outline of the coverage provisions and exclusions. It is not an insurance contract, nor part of the insurance policy/certificate. You will find complete coverage details in the policy/certificate Also see state variations on pages 10-13. general exclusions

Benefits will not be paid for services or supplies that are not administered or ordered by a doctor and medically necessary to the diagnosis or treatment of an illness or injury, as defined in the policy. No benefits are payable for expenses:

For non-emergency services or supplies received from a provider who is not a network provider, except as specifically provided for by the policy.

For a preexisting condition--A condition:

(1) for which medical advice, diagnosis, care, or treatment was recommended or received within the 24 months immediately preceding the date the covered person became insured under the policy/certificate; or (2) that had manifested itself in such a manner that would have caused an ordinarily prudent person to seek medical advice, diagnosis, care, or treatment within the 12 months immediately preceding the date the covered person became insured under the policy/certificate.

A pregnancy existing on the effective date of coverage will also be considered a preexisting condition.

Note: Even if you have had prior Golden Rule coverage and your preexisting conditions were covered under that plan, they will not be covered under this plan.

That would not have been charged if you did not have insurance.

Incurred while your coverage is not in force.

Imposed on you by a provider (including a hospital) that are actually the responsibility of the provider to pay.

For services performed by an immediate family member.

That are not identified and included as covered expenses under the policy/certificate or are in excess of the eligible expenses.

For services that are not covered expenses.

For services or supplies that are provided prior to the effective date or after the termination date of the coverage.

For weight modification or surgical treatment of obesity, including wiring of the teeth and all forms of intestinal bypass surgery.

For breast reduction or augmentation.

For drugs, treatment, or procedures that promote conception.

For sterilization or reversals of sterilization.

For fetal reduction surgery or abortion (unless life of mother would be endangered).

For treatment of malocclusions, disorders of the temporomandibular Joint (TMJ) or craniomandibular disorders.

For modification of the physical body in order to improve psychological, mental, or emotional well-being, such as sex- change surgery.

Not specifically provided for in the policy, including telephone consultations, failure to keep an appointment, television expenses, or telephone expenses.

For marriage, family, or child counseling.

For standby availability of a medical practitioner when no treatment is rendered.

For hospital room and board and nursing services if admitted on a Friday or Saturday, unless for an emergency, or for medically necessary surgery that is scheduled for the next day.

For dental expenses, including braces and oral surgery, except as provided for in the policy/certificate.

For cosmetic treatment.

For reconstructive surgery unless incidental to or following surgery or for a covered injury, or to correct a birth defect in a child who has been a covered person since childbirth until the surgery.

For diagnosis or treatment of learning disabilities, attitudinal disorders, or disciplinary problems.

For diagnosis or treatment of nicotine addiction.

For charges related to, or in preparation for, tissue or organ transplants, except as expressly provided for under Transplant Services.

For high-dose chemotherapy prior to, in conjunction with, or supported by ABMT/BMT, except as specifically provided under the Transplant Expense Benefits provision.

For eye refractive surgery, when the primary purpose is to correct nearsightedness, farsightedness, or astigmatism.

While confined for rehabilitation, custodial care, educational care, nursing services, or while at a residential treatment facility, except as provided for in the policy/ certificate.

For eyeglasses, contact lenses, hearing aids, eye refraction, visual therapy, or any exam or fitting related to these devices, except as provided for in the policy/ certificate.

Due to pregnancy (except complications), except as provided in the policy/certificate.

For diagnostic testing while confined primarily for well- baby care, except as provided in the policy/certificate.

For treatment of mental disorders or substance abuse including court-ordered treatment for programs, except as provided in the policy/certificate.

For preventive care or prophylactic care, including routine physical examinations, premarital examinations, and educational programs, except as provided in the policy/ certificate.

Incurred outside of the U.S., except for emergency treatment.

Resulting from declared or undeclared war, intentionally self-inflicted bodily harm (whether sane or insane); or participation in a riot or felony (whether or not charged).

For or related to durable medical equipment or for its fitting, implantation, adjustment or removal or for complications therefrom, except as provided for in the policy/certificate.

For outpatient prescription drugs, except as provided for in the policy/certificate.

For surrogate parenting.

For treatments of hyperhidrosis (excessive sweating).

For alternative treatments, except as specifically covered by the policy/certificate, including: acupressure, acupuncture, aromatherapy, hypnotism, massage therapy, rolfing, and other alternative treatments defined by the Office of Alternative Medicine of the National Institutes of Health.

Resulting from or during employment for wage or profit, if covered or required to be covered by workers' compensation insurance under state or federal law. If you entered into a settlement that waives your right to recover future medical benefits under a workers' compensation law or insurance plan, this exclusion will still apply.

Resulting from intoxication, as defined by state law where the illness or injury occurred, or while under the influence of illegal narcotics or controlled substances, unless administered or prescribed by a doctor.

For joint replacement, unless related to an injury covered by the policy/certificate.

For non-emergency treatment of tonsils, adenoids, hemorrhoids or hernia.

For injuries sustained during or due to participating, instructing, demonstrating, guiding, or accompanying others in any of the following: sports (professional, or semi- professional, or intercollegiate except for intramural), parachute jumping, hang-gliding, racing or speed testing any motorized vehicle or conveyance, scuba/skin diving (when diving 60 or more feet in depth), skydiving, bungee jumping, or rodeo sports.

For injuries sustained during or due to participating, instructing, demonstrating, guiding, or accompanying others in any of the following if the covered person is paid to participate or to instruct: operating or riding on a motorcycle, racing or speed testing any non-motorized vehicle or conveyance, horseback riding, rock or mountain climbing, or skiing.

For injuries sustained while performing the duties of an aircraft crew member, including giving or receiving training on an aircraft.

For vocational or recreational therapy, vocational rehabilitation, or occupational therapy, except as provided for in the policy/certificate.

Resulting from experimental or investigational treatments, or unproven services. ____ [From Bloomberg Businessweek, 2014-01-10] The Trouble With Short-Term Health Plans in the Age of Obamacare (By John Tozzi)

If you're shopping for health insurance, you may get a pitch for something called a short-term medical plan. These policies have been around forever and are aimed at recent college grads, people between jobs, and new employees waiting for group benefits to kick in. They're marketed by major insurers including UnitedHealthcare Services, Humana, some Blue Cross and Blue Shield carriers, and many smaller companies.

Short-term plans have become more visible as some insurers and brokers take advantage of the hoopla surrounding the Affordable Care Act to market them as alternatives to the policies available on the state and federal exchanges. Although the plans look a little like those approved under Obamacare, they provide less coverage and don't have to adhere to the same rules. The companies are allowed to turn away patients who are sick and refuse to cover preexisting conditions. They don't have to pay for preventative care and aren't required to renew a policy if a patient needs a lot of medical care. ``If you get sick, it's not going to take care of you,'' says Karen Pollitz, a senior fellow at the Kaiser Family Foundation, a health researcher.

The short-term plans also don't satisfy the Obamacare requirement that people have adequate coverage, so people who buy them face the same tax penalties as the uninsured. Twenty percent of short-term policyholders believed, wrongly, that their coverage would be adequate under the ACA, according to a survey published in September by EHealth, an online brokerage that sells conventional and short-term policies. An additional 64 percent said they weren't sure.

There's plenty of cause for the confusion. Assurant, one of the larger sellers of the temporary medical plans, says on its website that ``these plans do not meet minimum essential coverage requirements'' and customers may face tax penalties. But insurance agency Liberty Medicare in Wynnewood, Pa., called short-term plans ``a viable alternative to Obamacare plans'' in a recent blog post, although the company also noted that ``their benefits are not as broad as Obamacare benefits.'' Even if the policies exclude preexisting conditions, says president Gregory Lazarev, for ``healthy people who are not entitled to subsidies, it makes perfect sense to go and buy a short-term plan.''

20 Percent of short-term policy holders wrongly believe their plan meets Obamacare standards.

``There definitely are some companies out there that are aggressively marketing these and [similar] policies,'' Pollitz says. One making expansive claims is Health Insurance Innovations, which connects consumers with short-term policies from third-party insurers. The Tampa company, which raised $65 million in an initial offering about a year ago, is expecting a boost from the ACA, even though its plans don't meet the law's requirements for adequate coverage. ``We want to be ready to take full advantage of this unprecedented degree of market expansion,'' Chief Executive Officer Michael Kosloske said in a November earnings call. In an interview, Kosloske says: ``Our benefits are the same or better than what you're going to find, for example, on the exchanges.''

A sample policy sold by Kosloske's company suggests otherwise. Unlike ACA plans, it doesn't cover immunizations and routine physicals, outpatient prescription drugs, preexisting conditions, pregnancy or childbirth, sports injuries, substance abuse treatment, allergies, or kidney disease. It also comes with a $2 million lifetime limit on benefits, a provision banned under Obamacare rules.

Buying the stripped-down, short-term policy could save a 30-year-old Florida man $1,123 in premiums over a year, compared with a typical bronze-level HMO plan from Humana. If he earns $46,000 a year, he'd have to pay about 41 percent of the savings in tax penalties for not having coverage authorized by the ACA. The penalty rate will double in 2015. If the hypothetical consumer earns $23,000 or less, federal subsidies would make up the difference between the price of the bronze plan and the short-term policy.

Kosloske points out that the bronze plan has exclusions, too, and a limited network--it doesn't pay anything if you see a doctor outside the plan. In the plan his company sells, ``covered benefits are paid the same way whether in or outside the broad and highly accessible provider network,'' he says. Pollitz advises consumers to stay away from short- term plans. ``It may cover your claims until your term of coverage runs out,'' she says. But for anyone who gets sick and hopes to renew, ``it's junk.''

The bottom line: Consumers buying cheaper, short-term health plans get limited benefits and still have to pay Obamacare penalties.

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