347 Pages of Regulations; 811 References to Mandates

This is hot off the press from Chris Jacobs:

HHS just released part of its Exchange regulations—a 244-page regulation regarding the establishment of Exchanges, and a separate 103-page regulation regarding risk adjustment.  While the Administration is trying to sell Exchanges as providing competition and flexibility, the 347 pages of regulations contain the word “require” a whopping 811 times (628 instances in the Exchange regulation, and 183 in the risk adjustment regulation).  It’s worth asking:  How flexible can a piece of regulation that has 811 separate references to mandates and requirements be?

As noted previously, the documents just released comprise only “part” of the regulations necessary for states to implement health insurance Exchanges under Obamacare.  Page 11 of the Exchange rule notes that most of the critical elements of Exchanges are NOT included in today’s regulations.

Comments (6)

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  1. Vicki says:


  2. Devon Herrick says:

    It’s difficult to fathom how HHS could think of enough to regulations to fill 347 pages. Do the regulations writers get paid by the page?

  3. Bruce says:

    Are we supposed to be surprised at this?

  4. Jeff says:


  5. Larry C. says:

    Is this a joke?

  6. Brian Williams. says:

    It is only going to get worse.