Beware the Rush to Presumption, Part A: Material Omissions in Regulatory Analyses for the Affordable Care Act's Interim Final Rules

98 Pages Posted: 27 Aug 2014

See all articles by Christopher J. Conover

Christopher J. Conover

Duke University - Center for Health Policy, Law and Management

Jerry Ellig

George Washington University - Regulatory Studies Center (deceased)

Date Written: January 5, 2012

Abstract

Federal agencies issued eight major interim final regulations in 2010 to quickly implement major provisions of the Affordable Care Act. This paper finds that the regulatory impact analyses for these regulations were seriously incomplete, often omitting significant benefits, costs, or regulatory alternatives. Analysis of equity was cursory at best.

Keywords: Affordable Care Act, Patient Protection and Affordable Care Act, Regulatory Impact Analysis, health, health care, health reform, health insurance

JEL Classification: D73, D78, I18, K23, L51

Suggested Citation

Conover, Christopher J. and Ellig, Jerry, Beware the Rush to Presumption, Part A: Material Omissions in Regulatory Analyses for the Affordable Care Act's Interim Final Rules (January 5, 2012). Available at SSRN: https://ssrn.com/abstract=2486930 or http://dx.doi.org/10.2139/ssrn.2486930

Christopher J. Conover

Duke University - Center for Health Policy, Law and Management ( email )

Box 90253
Durham, NC 27708
United States
919-428-4676 (Phone)
919-684-6246 (Fax)

Jerry Ellig (Contact Author)

George Washington University - Regulatory Studies Center (deceased) ( email )

805 21st St. NW
Washington, DC 20052
United States
703-375-9410 (Phone)

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