NoHLA is grateful to the 92 organizations that signed the letter of support submitted during the federal comment period for Washington’s Section 1332 Waiver Application. The 1332 waiver allows states to pursue innovative strategies while also retaining the basic protections of the Affordable Care Act (ACA). Washington’s waiver requests permission to allow immigrants access to high quality, affordable health insurance. A diverse coalition of national organizations including the American Medical Association, Center on Budget and Policy Priorities and AFL-CIO joined health industry stakeholders like Kaiser Permanente and Regence along with community providers including International Community Health Services and Asian Counseling and Referral Service in expressing their support. 

An estimated 23% of Washington state’s uninsured population cannot enroll in health insurance because of current federal restrictions. If the waiver is granted, more than 100,000 Washingtonians would have access to health and dental coverage through the Washington Health Benefit Exchange (HBE), the administrator of Washington’s health exchange under the ACA. The joint letter highlights that the waiver would enable Washington state to:

• improve health equity, addressing one of the root causes of the disproportionate uninsurance rates and poorer health outcomes many of Washington’s communities of color face today.
• remove federal barriers to health coverage, offering all residents the same opportunity to purchase Qualified Health Plans and Qualified Dental Plans. 
• invest state funds toward more affordable coverage for low-income residents, with no impact to the federal deficit. 
• improve the broader individual insurance market by lowering premiums and reducing application barriers that prevent families from applying for coverage together.
• address long-standing health inequities that have become more apparent with the pandemic, as immigrants and communities of color are disproportionately contracting, hospitalized for, and dying from COVID-19.

Eric Rodriguez, Senior Vice President of UnidosUS (formerly National Council of la Raza) submitted a support letter (at page 111 of the comments) that included actuarial data showing a positive effect on premiums because immigrant beneficiaries are “healthier than current marketplace participants” and will “generate fewer average health care costs.” Despite misconceptions, UnidosUS said:

• Two-thirds of undocumented immigrants have lived in the U.S. for more than 10 years, and 80% have been here for more than five years.
• The majority of undocumented immigrants speak English well or very well; 96% of those age 16 and older are either employed or outside the labor force because of such factors as full-time school attendance or full-time caretaking for minor children and other dependents; and nearly a third (28%) are homeowners.
• In families with undocumented immigrants, 42% of all family members are U.S. citizens—most often, children.
• Each year, undocumented workers pay $79.7 billion in federal taxes and $41 billion in state and local taxes. In addition, payroll taxes from their employers provide $17 billion in annual revenue for Social Security and $4 billion for Medicaid.

Ultimately, 427 comments were submitted during the federal comment period, including a joint letter from 52 Washington state Senators and Representatives (at p.120 of the comments). 

In preparation for the new program, the legislature provided $50,000 in FY 2022 and $700,000 in FY 2023 for community outreach. During the last meeting of the HBE’s Health Equity Technical Advisory Committee meeting, HBE Associate Director of Outreach Mary McHale presented on how it will use the funds to support immigrants’ access to coverage.

HBE will hold listening sessions through October across the state to understand the challenges to enrollment for the newly-eligible population, in partnership with Centro Rendu, Columbia Basin College, Columbia Basin Health Association, Communidades Sin Fronteras, Community for the Advancement of Family Education, First Fruits, Heritage University, Hispanic Business Professionals Association, Manzanita House, Migrant Recruiters, Para Las Nara, Raiz, Pasco Processing, South County Promotoras, Tyson Foods, University of Washington, Washington State University–Vancouver. Participants will be paid for their involvement.

In 2023, the HBE will embark on a health literacy campaign to support immigrant communities and ensure eligible individuals are ready to enroll when coverage becomes available next year. Efforts include outreach to help understand the value of health insurance, how to access insurance, and where to find  assistance in languages other than English.Now, we are anxiously awaiting word from federal agencies regarding approval. A summary of Washington’s waiver application and materials is available on the HBE website. More information about 1332 waivers is here.