Health care reform in the United States

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Health care reform in the United States
General

Health care reform in the United States in 2010 was enacted nationally and most recently in two bills: the Patient Protection and Affordable Care Act which became law on March 23, 2010[1][2] and was shortly thereafter amended by the Health Care and Education Reconciliation Act of 2010 (H.R. 4872) (which became law on March 30). No Republicans voted in favor of either bill.[3]

Reuters and CNN summarized the March 2010 reforms and the year in which they take effect.[4][5]

Contents

[edit] History of national reform efforts

Here is a summary of reform achievements at the national level. For failed efforts, State based efforts, native tribes services and more details generally, see the main article History of health care reform in the United States.

[edit] Key reform drivers for the 2010 reforms

Uninsured Americans, with the numbers shown here from 1987 to 2008, are a major driver for reform efforts

Just before the passage of the bill, President Obama gave a speech at a rally in Pennsylvania in which he outlined the key elements of his reforms and why he felt it was imperative for Congress to vote for the legislation.[10]

[edit] Extend coverage through insurance mandate

The law includes health-related provisions to take effect over the next four years, including expanding Medicaid eligibility for people making up to 133% of the federal poverty level (FPL),[11] subsidizing insurance premiums for people making up to 400% of the FPL ($88,000 for family of 4 in 2010) so their maximum "out-of-pocket" payment for annual premiums will be on sliding scale from 2% to 9.8% of income,[12][13] providing incentives for businesses to provide health care benefits, prohibiting denial of coverage and denial of claims based on pre-existing conditions, establishing health insurance exchanges, prohibiting insurers from establishing annual coverage caps, and support for medical research. The new law mandates that by 2014, people must have adequate insurance coverage or else pay a fine. It is estimated will reduce the number of the uninsured from 19% of all residents in 2010 to 8% by 2016.[14] To achieve this the new law provides subsidies to encourage smaller employers to buy coverage for their workers and makes it easier to qualify for Medicaid. For those not on a government program such as Medicare or who do not get employer sponsored insurance, direct subsidies will help those on lower incomes to purchase insurance through a new on-line exchange, an internet State run market place, where there will be like-for-like price transparency of insurance company offerings. This is expected to improve price competition between insurers. The 8% figure of uninsured are expected to be mostly illegal immigrants (5%), who are not eligible for subsidies, and the remaining 3% will be those who exercise their freedom not to be insured and who opt instead to pay the fine.[14][15]

The new law aims to offset the cost of the insurance subsidies from savings to be made by reducing the problem of the medically uninsured. Approximately $43 billion was spent annually (in 2008) supporting a minimal level of health care services for the uninsured[16] and the average family was reckoned to be paying an additional $1,000 per year in insurance premiums to cover the uninsured.[17] The subsidies will most likely go to benefit the poorest and sickest (i.e. those who have the most difficulty in getting insurance currently) and who are most likely already in receipt of subsidies of one form or another (through uncompensated care schemes or by the higher costs levied on those with insurance). Making insurance mandatory rather than voluntary will tend to bring younger, healthier people into the insurance pool at a relatively low incremental cost which should reduce costs for everybody else in the pool.[18]

The new law should also improve the health of the nation by increasing insurance coverage. A 2009 Harvard study published in the American Journal of Public Health found more than 44,800 excess deaths annually in the United States associated with lack of insurance.[19][20] More broadly, a 1997 analysis estimated the number of people in the United States—insured and uninsured—who die per year because of lack of medical care was nearly 100,000.[21]

[edit] Guaranteed issue, community rating, individual mandate

Starting in 2014, the law will prohibit insurers denying coverage to sicker applicants, or imposing special conditions such as higher cost sharing, higher premiums, setting black-out periods, and rescinding policies for minor errors in the insurance application. This requirement is called guaranteed issue with community rating. Health care expenditures are highly concentrated with the most expensive 5% of the population accounting for half of aggregate health care spending, whereas the bottom 50% of spenders account for only 3%, which means that insurers' gains to be had from avoiding the sick greatly outweigh any possible gains from managing their care. As a consequence, insurers resources have been devoted to such avoidance at a direct cost to effective care management which is against the interests of the insured.[16] Instead of providing health security, the health insurance industry had, since the 1970s began to compete not on service and price but by becoming good risk differentiators, seeking to insure only those with good or normal health profiles and excluding those considered to be or to become unhealthy and therefore less profitable. According to a study from Cambridge Hospital, Harvard Law School and Ohio University, 62% of all 2007 personal bankruptcies in the United States were due to an inability to pay medical costs.[22] Many of these people forced into bankruptcy had medical insurance but the effect of caps, exclusions, and inability to fund or continue COBRA coverage was behind many of these bankruptcies. Medical impoverishment is almost unheard of in wealthy countries other than the US either because the state covers everyone or everyone is obliged by law to have insurance.[23]

Also starting in 2014, the law will require most people to have health insurance which meets a nationally approved minimum standard. This type of Health insurance mandate as a means of gaining near universal coverage and achieving community rating is used in Massachusetts law and is a feature of health care law in many other countries. The law requires all insurers to accept all applicants without personal medical underwriting and all applicants must be accepted for coverage without the imposition of special coverage rules for cost sharing and without the loading of premiums for pre-existing conditions. State-run internet based exchanges begin operations, providing a market place for small businesses and private individuals without health insurance to buy coverage on a group basis. These exchanges will be similar to others already in existence such as the Massachusetts Connector and that operating for Federal employees. Premiums in the exchange can only vary according to age, geographic region, coverage type (individual or family), or tobacco use.[24] The exchanges are expected to sharpen price competition by showing prices from each competing insurer in the exchange for like-for-like policies.

[edit] Make health insurance more effective

By forcing insurers to cover more of a person's health care costs by excluding lifetime and annual caps, cover first dollar costs for screenings and immunizations and preventing exclusions for necessary care. Ensure that no more than 15% of insurance premiums were swallowed up in insurance company overheads. Some insurance or health benefit schemes were considered wholly inadequate.[25]

[edit] Reduce the deficit

Reducing the deficit was another driver in health care reform. The reform legislation that passed was estimated by the Congressional Budget Office to reduce the deficit by $138 billion over 10 years.[26]

[edit] Eliminate overpayment in Medicare Advantage

Medicare Advantage plans are offered by private insurers and provide benefits over and above coverage in Medicare Parts A and B and receive funding from the Medicare fund for taking on Part A and B coverage. However, under a revised contract made during the previous Bush presidency, Medicare was overpaying the private insurers. MedPAC estimated the overpayment as being approximately $12 billion a year.[27] This meant that the average person in traditional Medicare was paying $90 a year as a subsidy to private insurers for which they received zero benefit and eliminating this overpayment would save $177 billion over ten years.[28]

[edit] Political positions of the main parties

The main political opposition to the passing of health care reform legislation in 2010 came from the Republican party and similar groupings on the right of American politics, such as the Tea party movement. In the most tightly contested vote for the final passage of the bill prior to reconciliation, not a single Republican in the House or Senate voted in favor of the bill.[29] This opposition was broadly based on objections to rises in taxation, especially of the so-called "Cadillac insurance plans" and the corollary increase in government spending on affordability subsidies. The GOP also objected to a new Health Insurance Rate Authority that would determine whether rate increases were "unreasonable" and to enforced rebates or premium reductions, and to any proposal that might have allowed government funds to subsidize abortion.[30] The opposition declared the law to be a "government takeover of health care", although the government did not propose taking over either the management of the health care system, which largely remains in private hands, nor was there ultimately legislation for a public insurer competitor. One version of an original draft prepared in the House of Representatives did call for a "public option" (a public insurer as one extra choice for consumers, competing against private insurers). Some Republicans have contested the constitutionality of the clause in the final legislation requiring people to purchase insurance. Both the government and the insurance industry have argued that this is a necessary prerequisite to achieve universality and equity for other insurance payers and to prevent people buying insurance only in time of need. The government argues that this is covered under the Commerce Clause, whereas detractors argue that this is wrong. As of 2010, this matter is still before the courts. The Associated Press has pointed out that some Republicans have flip-flopped on the issue such as Mitt Romney and Scott Brown. It also pointed out that past Republican figures such as Richard Nixon as well as some writers for the conservative think tank Heritage Foundation have supported a mandate.[31] The same is true of the concept of the insurance exchanges which the bill sets up, with some Republicans and the Heritage Foundation once supported.[32]

On the other side, Obama gave, in his State of the Union Address held just before the final passage of the bill, his reasons for taking on the issue of health care. He said it was because of the stories that he had heard from Americans with pre-existing conditions whose lives depend on getting insurance coverage; stories of patients being denied coverage, and of families with insurance who are just one illness away from financial ruin. He said that the approach being taken would protect every American from the worst practices of the insurance industry. He said it would give small businesses and uninsured Americans a chance to choose an affordable health care plan in a competitive market. He claimed that if they did nothing, millions of Americans would lose their health care this year and the deficit would grow. He said that premiums would increase and patients would be denied the care they need, and that small business owners would continue to drop coverage altogether. He said he would not walk away from those Americans, and he urged others in Congress not to do so either. He claimed that doctors and nurses in the health care system, who know the system best, consider this (legislation) a vast improvement over the status quo. He challenged anyone, from either party, with a better plan that would bring down premiums, bring down the deficit, cover the uninsured, strengthen Medicare for seniors, and stop insurance company abuses, to let him know, because he was eager to see it.[33]

[edit] Public policy debate

[edit] Abortion

A lot of the political debate centered on the prevention of the Federal funding of abortion. In the legislation that was finally passed the existing law on the preservation of the principle of no Federal funding for abortion (except in cases of rape, incest, or to preserve the life of the mother) was preserved.[34] The law requires people to pay for that element of coverage with a separate check to create a specific fund which is not subsidized and which is used to fund these services. State insurance commissioners are charged with policing this “segregation of funds”. Whether insurers in the exchanges can offer abortion coverage at all was left as a matter for individual States to decide. The default is that insurers will be allowed to offer abortion coverage as they do now unless a State passes legislation to the contrary.

[edit] Lobbying

According to Obama, America's health insurance industry has spent hundreds of millions of dollars to block the introduction of public medical insurance and stall other proposed legislation.[35] There are six registered health care lobbyists for every member of Congress.[36] The campaign against health care reform has been waged in part through substantial donations to key politicians. The single largest recipient of health industry political donations and chairman of the Senate Committee on Finance that drafted Senate health care legislation is Senator Max Baucus (D-MT).[37] A single health insurance company, Aetna, has contributed more than $110,000 to one legislator, Senator Joe Lieberman (ID-CT), in 2009.[38]

America's Health Insurance Plans, a lobby group funded by American private health insurance companies published its plans for health care reform in December 2008.[39] The key elements called for co-ordinated national strategy for health care with insurance regulation set in a national framework but enforced by the states.[39] It also called for a personal health care mandate requiring every American to have health insurance or face penalties. This, it said, was a necessary pre-requisite for guaranteed issue policies to prevent insurers from having to pre-screen applicants and set limits on coverage for pre-existing conditions, otherwise healthy people would put off buying insurance until they get sick.[39] It also called for the establishment of body to reform the payment system (including a shift from fee-for-service to fee-for-quality-outcomes), and a body to undertake Comparative effectiveness research because it admitted that the current system was not effective at providing value for money or even best practice and computerization and standardization of health care records and claims processing.[39] Most of the issues which AHIP called for in its plans have been implemented by the Obama administration and Congress in the reform process with the exception of a completely national framework for health care insurance regulation. Though the bill does place certain national rules for insurance to qualify as being "coverage" acceptable within the meaning of the individual mandate, states have retained the power under the reforms to regulate the industry and this was not put in a national framework.

[edit] Possible future reforms

The Patient Protection and Affordable Health Care Act 2010 contained provisions which allows the Centers for Medicare and Medicaid Services (CMS) to undertake pilot projects which, if they are successful could be implemented in future.

[edit] Universal health care

The universal health care proposal pending in Congress is called the United States National Health Care Act (H.R. 676, formerly the "Medicare for All Act.") The Congressional Budget Office and related government agencies scored the cost of a universal health care system several times since 1991, and have uniformly predicted cost savings,[40] probably because of the 40% cost savings associated with universal preventative care[41] and elimination of insurance company overhead costs.

[edit] Balancing doctor supply and demand

The Medicare Graduate Medical Education program regulates the supply of medical doctors in the U.S. By adjusting the reimbursement rates to establish more income equality among the medical professions, the effective cost of medical care can be lowered.

[edit] Bundled payments

A key project is one that could radically change the way the medical profession is paid for services under Medicare and Medicaid. The current system, which is also the prime system used by medical insurers is known as "fee for service" because the medical practitioner is paid only for the performance of medical procedures which, it is argued means that doctors have a perverse incentive to do more tests (which generates more income) which may not be in the patients' best long term interest. The current system encourages medical interventions such as surgeries and prescribed medicines (all of which carry some risk for the patient but increase revenues for the medical care industry) and does not reward other activities such as encouraging behavioral changes such as modifying dietary habits and quitting smoking, or follow-ups regarding prescribed regimes which could have better outcomes for the patient at a lower cost. The current fee-for-service system also rewards bad hospitals for bad service. Some[who?] have noted that the best hospitals have fewer re-admission rates than others, which benefits patients, but some of the worst hospitals have high re-admission rates which is bad for patients but is perversely rewarded under the fee-for-service system.

Projects at CMS are examining the possibility of rewarding health care providers through a process known as "bundled payments"[42] by which local doctors and hospitals in an area would be paid not on a fee for service basis but on a capitation system linked to outcomes. The areas with the best outcomes would get more. This system, it is argued, makes medical practitioners much more concerned to focus on activities that deliver real health benefits at a lower cost to the system by removing the perversities inherent in the fee-for-service system.

Though aimed as a model for health care funded by CMS, if the project is successful it is thought that the model could be followed by the commercial health insurance industry also.

[edit] 2010 Patient Protection and Affordable Care Act details

Key provisions of the health-care legislation passed in March 2010 are:[4]

[edit] Within one year of enactment (2010–2011)

[edit] Effective during 2011

[edit] Effective as of 2012

[edit] Effective as of 2013

[edit] Effective as of 2014

[edit] Effective 2015

[edit] Effective 2018

[edit] Legal challenges

As Congressional approval neared, opponents of health care reform shifted from parliamentary and procedural opposition to challenge the constitutionality of the legislation. The Virginia General Assembly passed the Virginia Health Care Freedom Act before Congress completed action on its bill. Governor Robert F. McDonnell signed that law on March 24, prior to House approval of the reconciliation bill.[54] The Virginia law prohibits any individual from being required to purchase health insurance. On March 17, 2010, Virginia Attorney General Ken Cuccinelli sent House Speaker Nancy Pelosi a letter threatening constitutional challenge to the enactment of the bill if the House used a self-implementing rule and deemed the bill, which had begun in the Senate, to pass.[55] On March 23, 2010, Cuccinelli filed Commonwealth v. Sebelius in the Federal District Court for the Eastern District of Virginia challenging the Constitutionality of the insurance requirement.[56] Also on March 23, 2010, the Attorney General of Florida, together with the States of South Carolina, Nebraska, Texas, Utah, Louisiana, Alabama, Michigan, Colorado, Pennsylvania, Washington, Idaho and South Dakota filed a joint law suit in a Florida district court also challenging the new law.[57]

Some Constitutional law professors and commentators in the press have opined that the lawsuits and state laws are unlikely to succeed.[58][59][60][61] However, other Constitutional law professors and other legal experts maintain that the health insurance mandate (the requirement that individuals purchase insurance, or face a penalty) is, in fact, unconstitutional.[62][63]

On August 2, 2010, District Court Judge Henry Hudson, presiding over Virginia's lawsuit challenging the Obama administration's health care reform package, denied the Justice Department's attempt to have that lawsuit dismissed, stating that Virginia's case raises Constitutional issues - mainly whether Congress has the right under the Commerce Clause to regulate and tax a person's decision not to participate in interstate commerce.[64]

[edit] Health reform and the 2008 presidential election

[edit] See also

[edit] Further reading

[edit] Books

[edit] Articles and links

[edit] References

  1. ^ Stolberg, Sheryl Gay (March 23, 2010). "Obama Signs Health Care Overhaul Bill, With a Flourish". The New York Times. http://www.nytimes.com/2010/03/24/health/policy/24health.html. Retrieved March 23, 2010. 
  2. ^ Pear, Robert; Herszenhorn, David M. (March 22, 2010). "Obama Hails Vote on Health Care as Answering ‘the Call of History’". The New York Times. http://www.nytimes.com/2010/03/22/health/policy/22health.html?hp. Retrieved March 22, 2010. "With the 219-to-212 vote, the House gave final approval to legislation passed by the Senate on Christmas Eve." 
  3. ^ Lochhead, Carolyn (March 22, 2010). "Houses passes health care bill 219-212". San Francisco Chronicle. Archived from the original on March 23, 2010. http://www.webcitation.org/5oS1boYV0. Retrieved March 23, 2010. "No Republicans supported the bill." 
  4. ^ a b Reuters-Factbox-U.S. Healthcare Bill Would Provide Immediate Benefits-March 19, 2010
  5. ^ CNN-Timeline-When Healthcare Reform Will Affect You-March 23, 2010
  6. ^ http://seniorjournal.com/NEWS/2000%20Files/Aug%2000/FTR-08-04-00MedCarHistry.htm Brief History of Medicare
  7. ^ Robert M. Ball, the then Deputy Director of the Bureau of Old-Age and Survivors Insurance in the Social Security Administration had defined the major obstacle to financing health insurance for the elderly several years earlier: the high cost of care for the aged and the generally low incomes of retired people. Because retired older people use much more medical care than younger, employed people, an insurance premium related to the risk for older people needed to be high, but if the high premium had to be paid after retirement, when incomes are low, it was an almost impossible burden for the average person. The only feasible approach, he said, was to finance health insurance in the same way as cash benefits for retirement, by contributions paid while at work, when the payments are least burdensome, with the protection furnished in retirement without further payment. http://www.ssa.gov/history/churches.html The role of Social Insurance in preventing economic dependency Robert Ball speech 1961
  8. ^ "An Employee's Guide to Health Benefits Under COBRA: The Consolidated Omnibus Budget Reconciliation Act of 1986," United States Department of Labor, Reprinted September 2006
  9. ^ SCHIP State Childrens Health Insurance Information Center
  10. ^ President's speech prior to passage of the legislation
  11. ^ a b "5 key things to remember about health care reform". CNN. March 25, 2010. http://www.cnn.com/2010/HEALTH/03/25/health.care.law.basics/index.html. 
  12. ^ a b "Policies to Improve Affordability and Accountability". The White House. http://www.whitehouse.gov/health-care-meeting/proposal/whatsnew/affordability. 
  13. ^ "Health Care Reform Bill 101". The Christian Science Monitor. http://www.csmonitor.com/USA/Politics/2010/0320/Health-care-reform-bill-101-Who-gets-subsidized-insurance. 
  14. ^ a b CBO reconciliation bill adjustments
  15. ^ Mark Trumbull, "Obama signs health care bill: Who won't be covered?"
  16. ^ a b MMS: Error
  17. ^ Meet the Press-Transcript of Sept 13 2009-Dick Durbin Statement
  18. ^ The Individual Mandate — An Affordable and Fair Approach to Achieving Universal Coverage NEJM article
  19. ^ American Journal of Public Health | December 2009, Vol 99, No.12
  20. ^ State-by-state breakout of excess deaths from lack of insurance
  21. ^ Woolhandler S, Himmelstein DU (March 1997). "Costs of care and administration at for-profit and other hospitals in the United States". The New England Journal of Medicine 336 (11): 769–74. doi:10.1056/NEJM199703133361106. PMID 9052656. 
  22. ^ Himmelstein DU, Thorne D, Warren E, Woolhandler S (August 2009). "Medical bankruptcy in the United States, 2007: results of a national study". The American Journal of Medicine 122 (8): 741–746. doi:10.1016/j.amjmed.2009.04.012. PMID 19501347. Lay summary – Medical News Today (June 5, 2009). 
  23. ^ [Reid TR. Interviews with leading health policy experts in several nations. "PBS - Interviews with leading health policy experts in several nations."]. Reid TR. Interviews with leading health policy experts in several nations.. 
  24. ^ HEALTH INSURANCE EXCHANGES AND THE AFFORDABLE CARE ACT: KEY POLICY ISSUES The Commonwealth Fund
  25. ^ http://abcnews.go.com/GMA/ConsumerNews/elisabeth-leamy-inadequate-health-insurance-deals/story?id=9722179&page=1 ABC news report on inadequate health benefit plans
  26. ^ Konrad, Walecia. The New York Times. http://topics.nytimes.com/top/news/health/diseasesconditionsandhealthtopics/health_insurance_and_managed_care/health_care_reform/index.html?scp=1-spot&sq=health%20care%20reform&st=cse. 
  27. ^ 2009 MedPAC Report Executive Summary
  28. ^ Health Care eform info for Seniors HHS
  29. ^ Both House vote and Senate vote had zero Republican support. Washington Post
  30. ^ Latest White House Health Care Proposal: The Same Big Government Takeover GOP statement of objection. Feb 22 2010
  31. ^ New health insurance requirement ... was GOP idea AP report in the NY Daily News
  32. ^ Health Official: 'Obamacare' Was Once 'Romneycare' CBS News (ex AP)
  33. ^ http://abcnews.go.com/video/playerIndex?id=9683034 ABC news video of the section of the State of the Union Address on health care.
  34. ^ Prohibit use of federal money for abortions, except as allowed by current law New York TimesMarch 22, 2010
  35. ^ "Remarks of Senator Barack Obama: Taking Our Government Back". http://www.barackobama.com/2007/06/22/remarks_of_senator_barack_obam_17.php. 
  36. ^ Salant, Jonathon and O’Leary, Lizzie. "Six Lobbyists Per Lawmaker Work on Health Overhaul" Bloomberg.com. August 14, 2009
  37. ^ McGreal, Chris (2009-10-01). "Revealed: millions spent by lobbyists fighting Obama health reforms". The Guardian (London). http://www.guardian.co.uk/world/2009/oct/01/lobbyists-millions-obama-healthcare-reform. Retrieved 2010-02-05. 
  38. ^ Mobilization for Health Care for All (November 5, 2009). "Nine Americans Jailed This Morning When They Tried to Confront Senator Joe Lieberman for Accepting Insurance Company Money". Press release. http://www.commondreams.org/newswire/2009/11/05-10. Retrieved 2010-03-23. 
  39. ^ a b c d Now is the Time for Health Care Reform: A Proposal to Achieve Universal Coverage, Affordability, Quality Improvement and Market Reform, America's Health Insurance Plans, Dec 2008
  40. ^ Physicians for a National Health Program (January, 2008) "Single Payer System Cost?" pnhp.org
  41. ^ Hogg, W., et al. (2005) "Cost savings associated with improving appropriate and reducing inappropriate preventive care: cost-consequences analysis" BMC Health Services Research 5:20
  42. ^ http://www.hfma.org/Templates/InteriorMaster.aspx?id=22682 The Medicare Bundled Payment Pilot Program: Participation Considerations
  43. ^ U.S. Department of Health and Human Services (June 28, 2010). "Patient Protection and Affordable Care Act; Requirements for Group Health Plans and Health Insurance Issuers Under the Patient Protection and Affordable Care Act Relating to Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections; Final Rule and Proposed Rule". Federal Register 75 (123): 37187–37241. http://edocket.access.gpo.gov/2010/2010-15278.htm. Retrieved July 26, 2010. 
  44. ^ "Healthcare Law Includes Tax Credit, Form 1099 Requirement". http://www.ppbmag.com/Article.aspx?id=5436. 
  45. ^ "Health Care Bill Brings Major 1099 Changes". http://www.theapchannel.com/accounts-payable/node/522. 
  46. ^ a b "Instructions for Form 1099-MISC". http://www.irs.gov/pub/irs-pdf/i1099msc.pdf. 
  47. ^ "Costly changes to 1099 reporting in health care law". http://www.accountingweb.com/topic/tax/costly-changes-1099-reporting-health-care-bill. 
  48. ^ "Health Care Reform Bill 101". The Christian Science Monitor. http://www.csmonitor.com/USA/Politics/2010/0320/Health-care-reform-bill-101-Who-gets-subsidized-insurance. 
  49. ^ "Patient Protection and Affordable Care Act/Title I/Subtitle E/Part I/Subpart A". http://en.wikisource.org/wiki/Patient_Protection_and_Affordable_Care_Act/Title_I/Subtitle_E/Part_I/Subpart_A. 
  50. ^ "Patient Protection and Affordable Care Act/Title I/Subtitle E/Part I/Subpart A:Premium Calculation". http://en.wikisource.org/wiki/Patient_Protection_and_Affordable_Care_Act/Title_I/Subtitle_E/Part_I/Subpart_A#appl_pct. 
  51. ^ "Refundable tax credit". http://hungerreport.org/2010/report/chapters/two/taxes/refundable-tax-credits. 
  52. ^ a b "An Analysis of Health Insurance Premiums Under the Patient Protection and Affordable Care Act". http://www.cbo.gov/ftpdocs/107xx/doc10781/11-30-Premiums.pdf. 
  53. ^ "Kaiser Family Foundation:Health Reform Subsidy Calculator -- Premium Assistance for Coverage in Exchanges/Gateways". http://healthreform.kff.org/SubsidyCalculator.aspx. 
  54. ^ "Governor McDonnell Signs Virginia Healthcare Freedom Act Legislation". http://www.governor.virginia.gov/news/viewRelease.cfm?id=88. Retrieved 2010-03-26. 
  55. ^ "Letter from Cuccinelli to Pelosi". http://www.oag.state.va.us/PRESS_RELEASES/Cuccinelli/Pelosi%20letter%203-17-10.pdf. Retrieved 2010-03-26. 
  56. ^ "Compliant". http://www.oag.state.va.us/PRESS_RELEASES/Cuccinelli/Comm%20v.%20Sebelius%20-%20Complaint%20filed%20with%20Court%20_323_10.pdf. Retrieved 2010-03-26. 
  57. ^ ARIANE de VOGUE and DEVIN DWYER (March 23, 2010). "States Launch Legal Challenge to Health Care Law". ABC News. http://abcnews.go.com/Politics/HealthCare/states-launch-legal-challenge-health-care-law/story?id=10178015. Retrieved 2010-03-26. 
  58. ^ Brendon Farrington, White House, experts: Health care suit will fail," Associated Press (March 23, 2010).
  59. ^ Mike Norman, "Give me liberty or give me mandatory health insurance," Fort Worth Star-Telegram (March 25, 2010).
  60. ^ Denise Lavoie, Opponents take last stand on health care bill, Associated Press (March 22, 2010).
  61. ^ Edward Fitzpatrick, Legal scholars say health-care bill is constitutional, Providence Journal (March 25, 2010).
  62. ^ George Mason University School of Law, Somin: Healthcare's Individual Mandate Unconstitutional, (June 22, 2010).
  63. ^ Professor Ilya Somin, Obamacare’s Unconstitutional Individual Mandate, (June 21, 2010).
  64. ^ Felberbaum, Michael (August 2, 2010). "Va. health care reform lawsuit clears 1st hurdle". Associated Press. The Washington Times. http://www.washingtontimes.com/news/2010/aug/2/va-health-care-reform-lawsuit-clears-1st-hurdle/. Retrieved 2010-10-14. 

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