3 things AHA is asking of the National Association of Insurance Commissioners

By Dave Pearson / September 1, 2026

The American Hospital Association is urging a multi-industry setter of insurance standards to paint a comprehensive picture of healthcare affordability as it informs state officials about healthcare costs.

In a letter sent to the attention of a healthcare-affordability working group within the National Association of Insurance Commissioners Aug. 31, AHA senior VP Ashley Thompson, MHA, asks members to make sure the group’s advisements on cost savings reduce consumers’ total financial burden.

The temptation may exist among policymakers, Thompson suggests, to home in on particular isolated measures such as premium reductions or payer savings. 

Another danger, she notes, may come in the form of pressures to “shift costs, limit access to care or create other unintended consequences”—even if only inadvertently. 

Thompson spends the bulk of the appeal pushing the working group’s chair and vice chair, respectively Kate Harris, MPA, and Kevin Beagan, MPP, MPH, to place three key items on the group’s to-do list as it refines NAIC’s six issue briefs on healthcare affordability for regulators and policymakers. 

 1. Apply a comprehensive total affordability framework, including a common definition of affordability.

A total affordability framework should “account for a policy’s effects, whether intended or not, on things like administrative burden, market competition and patients’ ability to access healthcare services,” the AHA’s Thompson writes. “Regulators and policymakers should consider who realizes the savings, whether they reduce the total cost of care and whether they create additional costs or access barriers elsewhere in the healthcare system.” 

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‘Applying a total affordability framework would help policymakers distinguish between policy options that produce sustainable improvements in affordability and those that primarily reallocate costs or financial risk among patients, employers, providers, insurers or government programs.’

 2. Provide a balanced assessment of each policy option’s benefits, limitations and tradeoffs.

“Each issue brief should provide a balanced description of the material benefits, limitations, implementation considerations and potential unintended consequences of the policy options under discussion,” Thompson states. “The briefs should not focus exclusively on intended benefits, projected payer savings or potential premium effects without examining who benefits, who bears the costs and how the policy may affect consumers’ access to care.”

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‘A balanced presentation does not require the working group to endorse or oppose a particular policy option. Instead, it should provide regulators and policymakers with sufficient information to determine the circumstances in which an option may be appropriate, the safeguards that may be needed and the tradeoffs that could accompany implementation.’

 3. Specifically account for the role of health plan practices in determining affordability and access.

Health plans “play a significant role in determining the affordability of coverage and consumers’ ability to obtain covered services,” Thompson emphasizes. “Benefit design, cost-sharing requirements, network configuration, utilization management requirements and processes, claims administration, coverage policies, administrative requirements and reimbursement practices all affect what consumers ultimately pay and whether they can obtain timely access to care.”

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‘Focusing narrowly on premiums as a distinct measure of affordability risks overlooking consumers’ actual cost exposure and the extent to which their coverage provides meaningful access to care.’