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Bill intelligence

Small employers get cheaper health plans—but at whose cost?

S. 1847 — Association Health Plans Act · Filed by Rand Paul (R-KY) · 6 cosponsors · Introduced May 21, 2025 · Referred to committee

65%
Transparency
Typical bill: 82%
35/100
Hidden-provision risk
Typical bill: 15/100
High concernHealth Insurance Regulatory Arbitrage

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What it does

This bill amends federal labor law to allow groups or associations of employers—including self-employed individuals—to band together to offer health insurance as a single entity, bypassing some state insurance regulations. The bill lets these association health plans use modified community rating (pooling claims across members) and risk-adjust premiums by employer, while maintaining federal protections against discrimination based on health status and pre-existing conditions. The stated intent is to expand affordable health coverage options for small employers and self-employed workers.

Why we flagged it

The bill's core mechanism is to create a new class of health plans that operate under federal ERISA rules while potentially evading state insurance regulation, solvency requirements, and consumer protections. This is regulatory arbitrage, not a straightforward expansion of coverage.

What the text implies

  • Association plans may attract younger, healthier members, leaving traditional small-group and individual markets with older, sicker pools and higher premiums—a form of adverse selection that harms those left behind.
  • The bill allows risk-adjustment by employer member, meaning sicker employers pay higher premiums within the same plan, potentially pricing out small employers with older or less healthy workforces.

The full analysis lists 5 implications of this text.

Who stands to gain

health insurance companies (through reduced state regulation and new market segments); third-party administrators and brokers (managing association plans); large employers (who can form associations to reduce per-employee costs)

Correlative observation from public records — not evidence of coordination or wrongdoing, and not financial advice.
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Quorum analysis of the full bill text · 119th Congress · public record