COST ESTIMATE OF H.R. 2528, ASSOCIATION HEALTH PLANS ACT

On 2026-09-16, Representative Tim Walberg (R-MI-5) delivered a floor speech titled "COST ESTIMATE OF H.R. 2528, ASSOCIATION HEALTH PLANS ACT" in the House.

COST ESTIMATE OF H.R. 2528, ASSOCIATION HEALTH PLANS ACT

Congressional Record, Volume 172 Issue 146 (Wednesday, September 16, 2026) [Congressional Record Volume 172, Number 146 (Wednesday, September 16, 2026)] [Extensions of Remarks] [Pages E947-E948] From the Congressional Record Online through the Government Publishing Office [ www.gpo.gov ] COST ESTIMATE OF H.R. 2528, ASSOCIATION HEALTH PLANS ACT ______ HON. TIM WALBERG of michigan in the house of representatives Wednesday, September 16, 2026 Mr. WALBERG. Mr. Speaker, I include in the Record the following cost estimate for H.R. 2528, Association Health Plans Act, prepared by the Congressional Budget Office, which was not made available to the Committee on Education and Workforce at the time of the filing of the legislative report. H.R. 2528, ASSOCIATION HEALTH PLANS ACT, AS REPORTED BY THE HOUSE COMMITTEE ON EDUCATION AND WORKFORCE ON DECEMBER 15, 2025 ------------------------------------------------------------------------ By fiscal year, millions of dollars-- ----------------------------------- 2026 2026-2031 2026-2036 ------------------------------------------------------------------------ Direct Spending (Outlays)........... 0 278 1,105 Revenues............................ 0 -1,143 -3,259 Increase or Decrease (-) in the 0 1,421 4,364 Deficit............................ Spending Subject to Appropriation 0 0 0 (Outlays).......................... ------------------------------------------------------------------------ Increases net direct spending in any of the four consecutive 10-year periods beginning in 2037? >$2.5 billion. Increases on-budget deficits in any of the four consecutive 10-year periods beginning in 2037? >$5 billion. Statutory pay-as-you-go procedures apply? Yes. Mandate Effects: Contains intergovernmental mandate? No. Contains private-sector mandate? No. The bill would: Revise the definition of ``employer'' in the Employee Retirement Income Security Act of 1974 to allow self-employed people and groups of employers without a common interest to sponsor association health plans (AHPs) Estimated budgetary effects would mainly stem from: Increases in tax deductions attributable to larger AHP enrollment among self-employed people Increases in federal subsidies for health insurance resulting from higher premiums in the nongroup and small-group health insurance markets because some self- employed people and small employers with lower-than-average health costs would enroll in AHPs Areas of significant uncertainty include: Anticipating employers' responses to the changing cost of health insurance Projecting patterns of health care use Bill summary: H.R. 2528 would revise the definition of ``employer'' in the Employee Retirement Income Security Act of 1974, to newly enable groups of self-employed people and groups of employers without a common interest to form association health plans (AHPs). Under current law, only groups of employers with a common interest may establish AHPs to purchase health insurance collectively. Such plans typically can offer their enrollees lowercost premiums than would be available in the nongroup or small-group markets. Estimated Federal cost: The estimated budgetary effects of H.R. 2528 are shown in Table 1. The costs of the legislation fall within budget function 550 (health). TABLE 1.--ESTIMATED BUDGETARY EFFECTS OF H.R. 2528 -------------------------------------------------------------------------------------------------------------------------------------------------------- By fiscal year, millions of dollars-- ---------------------------------------------------------------------------------------------------------------------- 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2026-2031 2026-2036 -------------------------------------------------------------------------------------------------------------------------------------------------------- INCREASES OR DECREASES (-) IN DIRECT SPENDING Estimated Budget Authority....... 0 -12 22 58 97 113 140 149 156 178 204 278 1,105 Estimated Outlays................ 0 -12 22 58 97 113 140 149 156 178 204 278 1,105 DECREASES IN REVENUES Estimated Revenues............... 0 -61 -143 -236 -326 -377 -387 -403 -416 -440 -470 -1,143 -3,259 On-Budget.................... -0 -54 -128 -209 -289 -336 -344 -358 -371 -392 -420 -1,016 -2,901 Off-Budget a................. 0 -7 -15 -27 -37 -41 -43 -45 -45 -48 -50 -127 -358 NET INCREASE IN THE DEFICIT FROM CHANGES IN DIRECT SPENDING AND REVENUES Effect on the Deficit............ 0 49 165 294 423 490 527 552 572 618 674 1,421 4,364 On-Budget.................... 0 42 150 267 386 449 484 507 527 570 624 1,294 4,006 Off-Budget a................. 0 7 15 27 37 41 43 45 45 48 50 127 358 -------------------------------------------------------------------------------------------------------------------------------------------------------- Sources: Congressional Budget Office; staff of the Joint Committee on Taxation. a Off-budget effects would arise from changes in Social SecurIty revenues. Basis of estimate: For this estimate, CBO assumes that the legislation will be enacted in fiscal year 2026 and that additional enrollment in AHPs will begin in calendar year 2027. Direct spending and revenues: H.R. 2528 would allow self- employed people and groups of employers to form AHPs without meeting the current-law requirement to have a common interest among members. CBO expects that enrollment in AHPs would increase under the bill because AHPs typically offer premiums that are less costly than the modified community-rated premiums available in the nongroup and small-group markets. In general, modified community-rated premiums can vary only on the basis of enrollees' age, location, and tobacco use. By contrast. AHPs can adjust premiums based on other factors related to members' health status. For example, members' occupations could be used as a proxy for health status. Because AHPs can adjust premiums to account for factors that more closely underlie the health of enrollees, a healthier self-employed person or a small employer with healthier-than- average workers could pay less for premiums through an AHP than they otherwise would for modified community-rated premiums in the nongroup and small-group markets. On the basis of a comparison of premiums under AHPs and under nongroup and small-group plans. CBO estimates that enacting H.R. 2528 would increase the number of people obtaining insurance through AHPs by about 725,000 per year, on average, over the 2027-2036 period. CBO estimates that under current law, about 155,000 of those people (or [[Page E948]] about 20 percent) have no health insurance and that the remaining 570,000 obtain insurance coverage in the nongroup or small-group markets. That estimate reflects factors that would limit the ability of employers and the self-employed to join or form AHPs. Those factors include requirements that an AHP have a minimum number of employee members, be formed for a purpose other than providing health insurance, and exist for more than two years before offering such benefits. CBO and the staff of the Joint Committee on Taxation (JCT) estimate that enacting H.R. 2528 would increase federal subsidies for health insurance for two reasons in particular: Some self-employed people who are uninsured under current law would take up insurance offered through AHPs, thereby increasing new claims for the tax deduction for health insurance for self-employed people. Slightly higher premiums in the nongroup and remaining small-group markets would result from people with lower-than-average health costs shifting to AHPs. That change would increase federal costs for the premium tax credit for health insurance purchased through the marketplaces established by the Affordable Care Act and would shift a portion of some employees' compensation from taxable wages to tax-favored health insurance for those insured in the small- group market. CBO and JCT estimate that these changes would increase direct spending, on net, by $1.1 billion and decrease revenues by $3.3 billion, for a total increase in the deficit of $4.4 billion over the 2026-2036 period. Uncertainty: CBO and JCT's estimates of the budgetary effects of H.R. 2528 are subject to uncertainty because of the difficulty in anticipating employers' responses to changes in health insurance costs and in projecting patterns of health care use, which affect premiums. The budgetary effects of enacting H.R. 2528 could be larger or smaller than estimated here. Pay-As-You-Go considerations: The Statutory Pay-As-You-Go Act of 2010 establishes budget-reporting and enforcement procedures for legislation affecting direct spending or revenues. The net changes in outlays and revenues that are subject to those pay-as-you-go procedures are shown in Table 2. Only on-budget changes to outlays or revenues are subject to pay-as-you-go procedures. TABLE 2.--CBO'S ESTIMATE OF THE STATUTORY PAY-AS-YOU-GO EFFECTS OF H.R. 2528, THE ASSOCIATION HEALTH PLANS ACT, AS REPORTED BY THE HOUSE COMMITTEE ON EDUCATION AND WORKFORCE ON DECEMBER 15, 2025 -------------------------------------------------------------------------------------------------------------------------------------------------------- By fiscal year, millions of dollars-- ---------------------------------------------------------------------------------------------------------------------- 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2026-2031 2026-2036 -------------------------------------------------------------------------------------------------------------------------------------------------------- NET INCREASES IN THE ON-BUDGET DEFICIT Pay-As-Your-Go Effect............ 0 42 150 267 386 449 484 507 527 570 624 1,294 4,006 Memorandum: Changes in Outlays........... 0 -12 22 58 97 113 140 149 156 178 204 278 1,105 Changes in Revenues.......... 0 -54 -128 -209 -289 -336 -344 -358 -371 -392 -420 -1,016 -2,901 -----------------------------------------------------------------------------------------

Referenced legislation: HR2528, HR2528, HR6703