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Board tables data‑submission penalty plan after members and stakeholders press for stronger deterrents

Health Care Affordability Board (Office of Health Care Affordability) · November 27, 2025
AI-Generated Content: All content on this page was generated by AI to highlight key points from the meeting. For complete details and context, we recommend watching the full video. so we can fix them.

Summary

The board reviewed a proposed penalty schedule (two flat untimely fines of $10,000 and $50,000 and a $5 per‑member failure‑to‑submit penalty that would double in year two) but deferred action to November after members and public commenters — including patient advocates and unions — argued the proposed amounts are too small to deter national plan noncompliance.

CJ Howard, assistant deputy director for health care spending targets, presented a detailed proposal to enforce HCAI’s data‑submission schedule: two flat untimely penalties (an initial $10,000 and an additional $50,000 if data remain missing by Nov. 1) and a per‑member failure‑to‑submit penalty proposed at $5 per member in year one that would double in subsequent noncompliant years.

Howard explained the rationale and scale using examples: the $5 per‑member figure would average approximately $2.7 million for a typical plan and could be substantially larger for…

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