Project 2025 Tracker / What’s done, what’s next

14. Department of Health and Human Services · Notable · Needs Congress

Codify expansion of association health plans, short-term plans, and HRAs

Attempted

470 14. Department of Health and Human Services

“Congress should build on the Trump Administration’s efforts to expand choices for small businesses and workers, both in and out of the exchanges, by codifying an expansion of association health plans, short-term health plans, and health reimbursement arrangements (including individual coverage HRAs).”

What has happened

  1. Attempted

    The House passed H.R. 1 with a health reimbursement arrangement title: sections 110201-110205 codified individual-coverage HRAs as "CHOICE arrangements", made participants eligible to buy exchange coverage with the funds, created an employer credit, extended eligibility to certain Medicare Part A entitlees and treated direct primary care arrangements. One chamber, so `attempted` under the Requires-Congress ladder. The Senate struck the CHOICE title from the reconciliation bill; only the direct primary care and HSA sections survived into Public Law 119-21. Association health plans and short-term plans were never in the bill: H.R. 2528, the Association Health Plans Act, was reported and placed on the Union Calendar on 2025-12-15 and has not been voted, which under playbook 3b is still not-started for that limb, and no short-term limited-duration insurance bill exists.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • The engrossed House text was opened and searched at https://www.govinfo.gov/content/pkg/BILLS-119hr1eh/html/BILLS-119hr1eh.htm: “CHOICE arrangement” appears 13 times, “health reimbursement” 8, “association health” 0.
  • House passage date confirmed from congress.gov’s record of actions on H.R. 1: “On passage Passed by the Yeas and Nays: 215 - 214, 1 Present (Roll no. 145)”, 2025-05-22.
  • Regulation rather than codification: the Marketplace Integrity and Affordability final rule (FR 2025-11606, 2025-06-25) and the 2027 Payment Notice discuss short-term plans and association health plans in passing, but the Quote asks Congress to codify, not the agencies to regulate.
Action
expand
Object
association health plans, short-term plans, and HRAs
ID
1293