First Annual Report on Health Care Sharing Plans and Arrangements from Colorado Division of Insurance

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Vincent Plymell

Report highlights the lack of benefits and protections in these arrangements.

DENVER - The Colorado Division of Insurance (DOI), part of the Department of Regulatory Agencies (DORA), has issued its first annual report on health care sharing plans and arrangements (HCSAs) in Colorado

For a number of years, the DOI has received many complaints and questions about HCSAs in Colorado, but the Division had limited information to address these concerns. This report, a result of 2022 legislation, HB22-1269, requires HCSAs operating in Colorado to report data annually to the Division to better understand these entities. This first report focuses on 2021 data.

Colorado is only the second state to require such information on HCSAs to be collected. This reporting represents a new avenue for consumer protection and transparency for the DOI, which is important as the Division has deep concerns about HCSAs in light of the complaints it has received from consumers. 

“The types of complaints we hear from consumers, typically centered around an HCSA not paying for a health care service, leaving the person stuck with a bill for thousands of dollars, are not just heartbreaking, but frustrating,” said Colorado Insurance Commissioner Michael Conway. “It shows me that people are clearly not getting the full story from the companies when they sign up for HCSAs. This reporting will help to shed light on HCSAs, and it becomes another tool in our consumer protection tool box.”

Added Leilani Russell, the Project Manager for Health Initiatives and Implementation for the DOI, “This report is a first step in finding out more about HCSAs and how they work. That means we can help Colorado consumers to know what they are getting, and more importantly, what they aren’t getting, when they look at HCSAs.”

HCSAs do not offer the same protections and benefits as Affordable Care Act (ACA) plans. Many of the HCSAs reported excluding benefits such as contraception coverage, mental health services, alcohol use disorder treatments, ADHD treatments, prescription drugs for chronic conditions, comprehensive reproductive health coverage (in most cases including coverage for abortion), and some pre-existing conditions. Many also reported excluding or placing limitations on maternity care unless the pregnant person had been a member of the HCSA’s highest membership tier for some previous amount of time .

Additionally, there are no guarantees that HCSA members will have their healthcare costs paid for through the “sharing” provisions in the groups. Some HCSAs specifically state that members are personally liable for payment of their medical bills. 

Some require that members first request health care providers and hospitals to reduce or write off health care bills. Other HCSAs actually require members, after members have paid HCSAs for coverage, to first request charity care and financial support from local governments and consumer support organizations in paying the member’s health care bills. For members who also have Medicare, HCSAs often require that members only use the HCSA after health care costs are submitted to Medicare.

Yet from the consumer complaints the DOI receives, it appears that consumers do not fully understand these limiting provisions, and that consumers often don’t understand what they are signing up for when they sign up for a HCSA. Typically, most of the consumers contacting the DOI believe they have something that works like a full ACA health insurance plan, with benefits to cover their health needs, and all of the protections that are part of such plans. 

Coloradans who experience problems with their HCSA should contact the Division of Insurance Consumer Services Team to ask questions and file a complaint: 303-894-7490 / / (click on “File a Complaint”).


About the Division of Insurance:

The Colorado Division of Insurance (DOI), part of the Department of Regulatory Agencies (DORA), regulates the insurance industry and assists consumers and other stakeholders with insurance issues. Visit for more information or call 303-894-7499 / toll free 800-930-3745

About DORA:

DORA is dedicated to preserving the integrity of the marketplace and is committed to promoting a fair and competitive business environment in Colorado. Consumer protection is our mission. Visit for more information or call 303-894-7855 / toll free 800-886-7675

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