[House Report 118-680]
[From the U.S. Government Publishing Office]


118th Congress  }                                              {   Report
                        HOUSE OF REPRESENTATIVES
 2d Session     }                                              { 118-680

======================================================================



 
                 CHRONIC DISEASE FLEXIBLE COVERAGE ACT

                                _______
                                

 September 17, 2024.--Committed to the Committee of the Whole House on 
            the State of the Union and ordered to be printed

                                _______
                                

Mr. Smith of Missouri, from the Committee on Ways and Means, submitted 
                             the following

                              R E P O R T

                             together with

                   DISSENTING AND SUPPLEMENTAL VIEWS

                        [To accompany H.R. 3800]

      [Including cost estimate of the Congressional Budget Office]

    The Committee on Ways and Means, to whom was referred the 
bill (H.R. 3800) to codify Internal Revenue Service guidance 
relating to treatment of certain services and items for chronic 
conditions as meeting the preventive care deductible safe 
harbor for purposes of high deductible health plans in 
connection with health savings accounts, having considered the 
same, reports favorably thereon with an amendment and 
recommends that the bill as amended do pass.

                                CONTENTS

                                                                   Page
  I. SUMMARY AND BACKGROUND...........................................2
          A. Purpose and Summary.................................     2
          B. Background and Need for Legislation.................     2
          C. Legislative History.................................     3
          D. Designated Hearing..................................     4
 II. EXPLANATION OF THE BILL..........................................4
          A. Services and Items for Chronic Conditions Treated as 
              Preventive Care (sec. 2 of the bill and Sec. 223 of 
              the Code)..........................................     4
III. VOTE OF THE COMMITTEE............................................6
 IV. BUDGET EFFECTS OF THE BILL.......................................7
          A. Committee Estimate of Budgetary Effects.............     7
          B. Statement Regarding New Budget Authority and Tax 
              Expenditures Budget Authority......................     7
          C. Cost Estimate Prepared by the Congressional Budget 
              Office.............................................     7
  V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE......14
          A. Committee Oversight Findings and Recommendations....    14
          B. Statement of General Performance Goals and 
              Objectives.........................................    14
          C. Information Relating to Unfunded Mandates...........    14
          D. Congressional Earmarks, Limited Tax Benefits, and 
              Limited Tariff Benefits............................    14
          E. Tax Complexity Analysis.............................    14
          F. Duplication of Federal Programs.....................    15
 VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED...........15
          A. Changes in Existing Law Proposed by the Bill, as 
              Reported...........................................    15
VII. DISSENTING VIEWS................................................16

    The amendment is as follows:
    Strike all after the enacting clause and insert the 
following:

SECTION 1. SHORT TITLE.

  This Act may be cited as the ``Chronic Disease Flexible Coverage 
Act''.

SEC. 2. SERVICES AND ITEMS FOR CHRONIC CONDITIONS TREATED AS PREVENTIVE 
                    CARE.

  (a) In General.--The additional preventive care services and items 
for chronic conditions that may be treated as preventive care for 
purposes of section 223(c)(2)(C) of the Internal Revenue Code of 1986 
as set forth in IRS Notice 2019-45 shall have the same force and effect 
as if included in the enactment of this Act.
  (b) No Inference.--To the extent not inconsistent with this section, 
no inference shall be made from subsection (a) with respect to such 
other rules or guidance as the Secretary has provided, or may provide, 
with respect to preventive services for purposes of section 
223(c)(2)(C) of such Code.

                       I. SUMMARY AND BACKGROUND


                         A. Purpose and Summary

    The bill, H.R. 3800, the ``Chronic Disease Flexible 
Coverage Act,'' as ordered reported by the Committee on Ways 
and Means on June 7, 2023, codifies IRS Notice 2019-45.

                 B. Background and Need for Legislation

    In order for an individual with a High Deductible Health 
Plan (HDHP) to make or receive contributions to an Health 
Savings Account (HSA), an individual cannot have disqualifying 
health coverage. An HDHP is a health insurance plan that 
satisfies certain requirements with respect to minimum 
deductibles and maximum out-of-pocket expenses. Generally, 
under section 223(c)(2)(A) of the Internal Revenue Code, an 
HDHP may not provide benefits for any year until the minimum 
deductible for that year is satisfied. However, section 
223(c)(2)(C) provides a safe harbor for the absence of a 
deductible for preventive care.
    In 2019, the Trump Administration expanded the list of 
services that an employer can cover before the deductible to 
include select low-cost preventive care that helps maintain 
health status for individuals with chronic conditions. This 
list includes 14 specific services that meet three criteria:
          1. The service or item is low-cost;
          2. There is medical evidence supporting high cost 
        efficiency (a large expected impact) of preventing 
        exacerbation of the chronic condition or the 
        development of a secondary condition; and
          3. There is a strong likelihood, documented by 
        clinical evidence, that with respect to the class of 
        individuals prescribed the item or service, the 
        specific service or use of the item will prevent the 
        exacerbation of the chronic condition or the 
        development of a secondary condition that requires 
        significantly higher cost treatments.
    IRS Notice 2019-45 includes the following services for 
individuals with the following conditions:

------------------------------------------------------------------------
 
------------------------------------------------------------------------
Preventive Care for Specified Conditions    For Individuals Diagnosed
                                             with
 
Angiotensin Converting Enzyme (ACE)         Congestive heart failure,
 inhibitors                                  diabetes, and/or coronary
                                             artery disease
Anti-resorptive therapy                     Osteoporosis and/or
                                             osteopenia
Beta-blockers                               Congestive heart failure and/
                                             or coronary artery disease
Blood pressure monitor                      Hypertension
Inhaled corticosteroids                     Asthma
Insulin and other glucose lowering agents   Diabetes
Retinopathy screening                       Diabetes
Peak flow meter                             Asthma
Glucometer                                  Diabetes
Hemoglobin A1c testing                      Diabetes
International Normalized Ratio (INR)        Liver disease and/or
 testing                                     bleeding disorders
Low-density Lipoprotein (LDL) testing       Heart disease
Selective Serotonin Reuptake Inhibitors     Depression
 (SSRIs)
Statins                                     Heart disease and/or
                                             diabetes
------------------------------------------------------------------------

    Because these new flexibilities were made available through 
agency action, the Committee believes it is necessary to codify 
the flexibilities so health insurance plans and plan sponsor 
can be confident this flexibility will remain, while ensuring 
the Secretary of Treasury continues to have authority to add 
additional services to the list, as necessary.

                         C. Legislative History


Background

    H.R. 3800 was introduced on June 5, 2023, and was referred 
to the Committee on Ways and Means.

Committee Hearings

    On Tuesday, May 16, 2023 the Committee held a Full 
Committee Hearing on ``Why Health Care is Unaffordable: The 
Fallout of Democrats' Inflation on Patients and Small 
Businesses''.

Committee Action

    The Committee on Ways and Means marked up H.R. 3800, the 
``Chronic Disease Flexible Coverage Act,'' on June 7, 2023, and 
ordered the bill, as amended, favorably reported (with a quorum 
being present).

                         D. Designated Hearing

    Pursuant to clause 3(c)(6) of rule XIII, the following 
hearings were used to develop and consider H.R. 3800:
          (1) Committee on Ways and Means Committee Hearing 
        ``Why Health Care is Unaffordable: The Fallout of 
        Democrats' Inflation on Patients and Small 
        Businesses''.

                      II. EXPLANATION OF THE BILL


A. Services and Items for Chronic Conditions Treated as Preventive Care 
             (sec. 2 of the Bill and Sec. 223 of the Code)


                              PRESENT LAW

Health savings accounts

    An individual may contribute to a health savings account 
(``HSA'') only if the individual is covered under a plan that 
meets the requirements for a high deductible health plan, as 
described below. An HSA is a tax-exempt trust or custodial 
account created exclusively to pay for the qualified medical 
expenses of the account holder and his or her spouse and 
dependents.\1\ The HSA rules allow deductible contributions to, 
and tax-exempt distributions from, HSAs for current medical 
expenses as well as an income tax exemption for earnings on HSA 
investments to be used for future medical expenses.
---------------------------------------------------------------------------
    \1\Sec. 223(d).
---------------------------------------------------------------------------
    Within limits,\2\ an eligible individual is allowed a 
deduction for contributions to an HSA made by or on behalf of 
the individual.\3\ Contributions to an HSA are excludible from 
an individual's income and from employment taxes if made by the 
individual's employer. Earnings in HSAs are not taxable.\4\ 
Distributions from an HSA for qualified medical expenses are 
not includible in the HSA beneficiary's gross income.\5\ 
Distributions from an HSA that are not used for qualified 
medical expenses are includible in the HSA beneficiary's gross 
income and are subject to an additional tax of 20 percent.\6\ 
The 20-percent additional tax does not apply if the 
distribution is made after the beneficiary dies, becomes 
disabled, or attains the age of Medicare eligibility (age 
65).\7\
---------------------------------------------------------------------------
    \2\For 2023, the basic limit on annual contributions that can be 
made to an HSA is $3,850 in the case of self-only coverage and $7,750 
in the case of family coverage. Rev. Proc. 2022-24, 2022-20 I.R.B. 
1075. The basic annual contributions limits are increased by $1,000 for 
individuals who have attained age 55 by the end of the taxable year 
(referred to as ``catch-up'' contributions). Sec. 223(b)(3).
    \3\A family member (or any other person) may make contributions to 
an HSA on behalf of an eligible individual. See Notice 2004 50, Q & A 
38, 2003 33, I.R.B. 196 (August 9, 2004).
    \4\Sec. 223(e).
    \5\Sec. 223(f)(1).
    \6\Sec. 223(f)(2), (4).
    \7\Sec. 223(f)(4).
---------------------------------------------------------------------------

High deductible health plans

    A high deductible health plan (``HDHP'') is a health plan 
that has an annual deductible of at least $1,500 (for 2023) for 
self-only coverage and twice this amount for family coverage 
($3,000 for 2023), and for which the sum of the annual 
deductible and other annual out-of-pocket expenses (other than 
premiums) for covered benefits does not exceed $7,500 (for 
2023) for self-only coverage and twice this amount for family 
coverage ($15,000 for 2023).\8\ These dollar thresholds are 
adjusted for inflation.\9\
---------------------------------------------------------------------------
    \8\Sec. 223(c)(2).
    \9\Sec. 223(g).
---------------------------------------------------------------------------
    An individual who is covered under an HDHP is eligible to 
contribute to an HSA if the individual is not also covered 
under a non-HDHP that provides coverage for any benefit 
(subject to certain exceptions) that is covered under the 
HDHP.\10\
---------------------------------------------------------------------------
    \10\Sec. 223(c)(1).
---------------------------------------------------------------------------
    Various types of coverage are disregarded for this purpose, 
including coverage of any benefit provided by permitted 
insurance, coverage (whether through insurance or otherwise) 
for accidents, disability, dental care, vision care, or long-
term care, as well as certain limited coverage through health 
flexible spending arrangements.\11\ Permitted insurance means 
insurance under which substantially all of the coverage 
provided relates to liabilities incurred under workers' 
compensation laws, tort liabilities, liabilities relating to 
ownership or use of property, or such other similar liabilities 
as specified by Treasury under regulations. Permitted insurance 
also means insurance for a specified disease or illness, and 
insurance paying a fixed amount per day (or other period) of 
hospitalization.\12\
---------------------------------------------------------------------------
    \11\Sec. 223(c)(1)(B).
    \12\Sec. 223(c)(3).
---------------------------------------------------------------------------
    Under a safe harbor, an HDHP is permitted to provide 
coverage for preventive care (within the meaning of section 
1861 of the Social Security Act, except as otherwise provided 
by the Secretary) before satisfaction of the minimum 
deductible.\13\ Internal Revenue Service (``IRS'') guidance 
provides a safe harbor for the types of coverage that 
constitute preventive care for this purpose.\14\
---------------------------------------------------------------------------
    \13\Sec. 223(c)(2)(C).
    \14\Notice 2004-23, 2004-15 I.R.B. 725 (April 12, 2004). See also 
Notice 2004-50, 2004-33 IRB 1 (August 9, 2004); Notice 2008-59, 2008-29 
I.R.B. 123 (July 21, 2008); Notice 2013-37, 2013-40 I.R.B. 293 
(September 30, 2013); Notice 2018-12, 2018-12 I.R.B. 441 (March 19, 
2018); and Notice 2019-45, 2019-32 I.R.B. 593 (August 5, 2019).
---------------------------------------------------------------------------

Preventive care

    As noted, IRS guidance provides a safe harbor for 
preventive care benefits allowed under an HDHP. The IRS defines 
preventive care as including, but not limited to (1) periodic 
health evaluations, including tests and diagnostic procedures 
ordered in connection with routine examinations, such as annual 
physicals; (2) routine prenatal and well-child care; (3) 
immunizations; (4) tobacco cessation programs; (5) obesity 
weight-loss programs; and (6) screening services (such as 
screening for cancer, heart and vascular diseases, infectious 
diseases, mental health conditions and substance abuse, 
metabolic, nutritional, and endocrine conditions, 
musculoskeletal disorders, obstetric and gynecologic 
conditions, pediatric conditions, and vision and hearing 
disorders). Although the guidance provides that preventive care 
does not generally include any service or benefit intended to 
treat an existing illness, injury, or condition (with the 
exception of chronic conditions, as described below), any 
treatment that is incidental or ancillary to a safe harbor 
preventive care service or screening (in situations where it 
would be unreasonable or impracticable to perform another 
procedure to treat the condition), such as the removal of 
polyps during a diagnostic colonoscopy, also falls within the 
safe harbor. In addition, drugs or medications are considered 
to be preventive care when taken by a person who has developed 
risk factors for a disease that has not yet manifested itself 
or not yet become clinically apparent, or to prevent the 
reoccurrence of a disease from which a person has recovered.
    Under a 2019 Executive Order, the Treasury Department was 
required to issue guidance to expand the ability of patients to 
select an HDHP that could be used with an HSA to cover, before 
the deductible, low-cost preventive care for individuals with 
chronic conditions.\15\
---------------------------------------------------------------------------
    \15\Executive Order 13877, ``Improving Price and Quality 
Transparency in American Healthcare to Put Patients First,'' 84 Fed. 
Reg. 30849 (June 27, 2019).
---------------------------------------------------------------------------
    Notice 2019-45\16\ expands the list of preventive care 
benefits permitted to be provided by an HDHP, before the 
deductible, to include specified preventive care for specified 
chronic conditions.
---------------------------------------------------------------------------
    \16\2019-32 I.R.B. 593 (August 5, 2019).
---------------------------------------------------------------------------
    Preventive care also encompasses such services that are 
required to be included by a group health plan or health 
insurance issuer offering group or individual health insurance 
coverage under section 2713 of the Public Health Service 
Act.\17\
---------------------------------------------------------------------------
    \17\Notice 2019-45 provides that ``[a]lthough this notice clarifies 
that benefits for the specified services and items for individuals with 
the specified chronic conditions listed in the Appendix are preventive 
care for purposes of section 223(c)(2)(C), it does not treat these 
services and items as preventive care required to be provided without 
cost sharing for purposes of section 2713 of the PHS Act.''
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    The Committee observes that having coverage under an HDHP 
that covers low-cost preventive care before the deductible for 
individuals with chronic conditions helps maintain these 
individuals' health status and prevents exacerbation of the 
condition or the development of a secondary condition. The 
Committee believes that encouraging chronic care management 
through current and expanding access to such preventive 
services will result in better health outcomes for individuals 
with chronic conditions.

                        EXPLANATION OF PROVISION

    The provision provides that the IRS Notice 2019-45 guidance 
describing the additional preventive care services and items 
for chronic conditions that, under Notice 2019-45, may be 
treated as preventive care for purposes of section 
223(c)(2)(C), has the same force and effect as if included in 
the enactment of this provision.
    To the extent not inconsistent with the provision, no 
inference may be made with respect to such other rules or 
guidance as the Secretary has provided, or may provide, with 
respect to preventive services for purposes of section 
223(c)(2)(C).

                             EFFECTIVE DATE

    The provision is effective on the date of enactment.

                       III. VOTE OF THE COMMITTEE

    Pursuant to clause 3(b) of rule XIII of the Rules of the 
House of Representatives, the following statement is made 
concerning the vote of the Committee on Ways and Means in its 
consideration of H.R. 3800, the ``Chronic Disease Flexible 
Coverage Act,'' on June 7, 2023.
    The bill, H.R. 3800, the ``Chronic Disease Flexible 
Coverage Act,'' as amended, was ordered favorably reported to 
the House of Representatives by a roll call vote of 34 yeas to 
6 nays (with a quorum being present).

----------------------------------------------------------------------------------------------------------------
           Representative              Yea     Nay    Present       Representative       Yea     Nay    Present
----------------------------------------------------------------------------------------------------------------
Mr. Smith (MO).....................      X   ......  .........  Mr. Neal.............      X   ......  .........
Mr. Buchanan.......................      X   ......  .........  Mr. Doggett..........  ......      X   .........
Mr. Smith (NE).....................      X   ......  .........  Mr. Thompson.........      X   ......  .........
Mr. Kelly..........................      X   ......  .........  Mr. Larson...........      X   ......  .........
Mr. Schweikert.....................      X   ......  .........  Mr. Blumenauer.......      X   ......  .........
Mr. LaHood.........................      X   ......  .........  Mr. Pascrell.........      X   ......  .........
Dr. Wenstrup.......................      X   ......  .........  Mr. Davis............  ......      X   .........
Mr. Arrington......................  ......  ......  .........  Ms. Sanchez..........  ......  ......  .........
Dr. Ferguson.......................      X   ......  .........  Mr. Higgins..........  ......      X   .........
Mr. Estes..........................      X   ......  .........  Ms. Sewell...........  ......      X   .........
Mr. Smucker........................      X   ......  .........  Ms. DelBene..........      X   ......  .........
Mr. Hern...........................  ......  ......  .........  Ms. Chu..............  ......      X   .........
Ms. Miller.........................      X   ......  .........  Ms. Moore............  ......      X   .........
Dr. Murphy.........................      X   ......  .........  Mr. Kildee...........      X   ......  .........
Mr. Kustoff........................      X   ......  .........  Mr. Beyer............      X   ......  .........
Mr. Fitzpatrick....................      X   ......  .........  Mr. Evans............      X   ......  .........
Mr. Steube.........................      X   ......  .........  Mr. Schneider........      X   ......  .........
Ms. Tenney.........................      X   ......  .........  Mr. Panetta..........      X   ......  .........
Mrs. Fischbach.....................      X   ......  .........
Mr. Moore..........................      X   ......  .........
Mrs. Steel.........................      X   ......  .........
Ms. Van Duyne......................      X   ......  .........
Mr. Feenstra.......................      X   ......  .........
Ms. Malliotakis....................      X   ......  .........
Mr. Carey..........................      X   ......  .........
----------------------------------------------------------------------------------------------------------------

                     IV. BUDGET EFFECTS OF THE BILL


               A. Committee Estimate of Budgetary Effects

    In compliance with clause 3(d) of rule XIII of the Rules of 
the House of Representatives, the following statement is made 
concerning the effects on the budget of the bill, H.R. 3800, as 
reported.
    The bill is estimated to have no effect on the Federal 
fiscal year budget receipts for the period 2023 through 2033.

B. Statement Regarding New Budget Authority and Tax Expenditures Budget 
                               Authority

    In compliance with clause 3(c)(2) of rule XIII of the Rules 
of the House of Representatives, the Committee states that the 
bill involves no new or increased budget authority. The 
Committee states further that the bill involves no new or 
increased tax expenditures.

      C. Cost Estimate Prepared by the Congressional Budget Office

    The following cost estimate was prepared by the CBO and the 
statement by CBO is provided.




    Bill summary: On June 7, 2023, the Committee on Ways and 
Means ordered nine bills to be reported. This document provides 
estimates for each piece of legislation.
    Generally, the legislation would:
           Permanently establish what is known as a 
        safe harbor, which allows high-deductible health plans 
        to provide telehealth services without making 
        participants ineligible to use health savings accounts;
           Modify certain reporting requirements for 
        employers and codify existing regulations or guidance 
        related to employment-based health insurance coverage;
           Designate certain airports as ports of entry 
        if they are within 30 miles of the southern or northern 
        border of the United States; and
           Require the Social Security Administration 
        (SSA) to take certain actions in the event of loss or 
        misuse of a Social Security number.
    Estimated Federal cost: The estimated direct spending and 
revenue effects of the legislation are shown in Table 1. The 
costs of the legislation fall within budget functions 650 
(Social Security), 750 (administration of justice), and 800 
(general government).
    Basis of estimate: For this estimate, CBO assumes that each 
bill will be enacted late in fiscal year 2023 and that spending 
of appropriated amounts will begin in fiscal year 2024. The 
Congressional Budget Act of 1974, as amended, stipulates that 
revenue estimates provided by the staff of the Joint Committee 
on Taxation (JCT) will be the official estimates for all tax 
legislation considered by the Congress. CBO, therefore, 
incorporates those estimates into its cost estimates of the 
effects of legislation.
    Direct spending: CBO estimates that one bill of the nine 
would affect direct spending: H.R. 3796 would designate as 
ports of entry certain airports within 30 miles of the southern 
or northern border of the United States. Under current law, 
Customs and Border Protection (CBP) collects customs user fees, 
including immigration user fees and fees collected under the 
Consolidated Omnibus Budget Reconciliation Act (COBRA), at 
designated ports of entry. Those fees, which are deposited into 
the Treasury as offsetting receipts, are classified as direct 
spending. CBO expects that fewer than five airports would be 
designated as ports of entry under the bill and that the 
increase in collections of customs user fees under the bill 
would be small.
    Therefore, CBO estimates that enacting H.R. 3796 would 
reduce net direct spending by less than $500,000 over the 2023-
2033 period.

  TABLE 1.--ESTIMATED EFFECTS ON DIRECT SPENDING AND REVENUES OF HEALTH CARE AND OTHER LEGISLATION ORDERED REPORTED BY THE HOUSE COMMITTEE ON WAYS AND
                                                                  MEANS ON JUNE 7, 2023
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                           By fiscal year, millions of dollars--
                                  ----------------------------------------------------------------------------------------------------------------------
                                    2023    2024     2025     2026     2027     2028     2029     2030     2031     2032     2033   2023-2028  2023-2033
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                            DECREASES (-) IN DIRECT SPENDING
 
H.R. 3796, a bill to provide for
 the extension of taxes funding
 the Airport and Airway Trust
 Fund and to require the
 designation of certain airports
 as ports of entry:
    Estimated Budget Authority...       0       *        *        *        *        *        *        *        *        *        *          *          *
    Estimated Outlays............       0       *        *        *        *        *        *        *        *        *        *          *          *
 
                                                                DECREASES (-) IN REVENUES
 
H.R. 1843, the Telehealth
 Expansion Act of 2023:
    Estimated Revenues...........       0       0     -225     -386     -471     -555     -605     -642     -681     -722     -766     -1,636     -5,053
        On-Budget................       0       0     -167     -293     -359     -422     -460     -487     -516     -547     -580     -1,240     -3,831
        Off-Budget...............       0       0      -58      -93     -112     -133     -145     -155     -165     -175     -186       -396     -1,222
H.R. 3801, the Employer Reporting
 Improvement Act:
    Estimated Revenues...........       0       0        *        *        *        *        *        *        *        *        *          *          *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Sources: Congressional Budget Office; staff of the Joint Committee on Taxation.
Components may not sum to totals because of rounding; * = between -$500,000 and zero.
Off-budget effects reflect decreases in payroll taxes for Social Security.

    Revenues: CBO and JCT estimate that two bills would affect 
revenues over the 2023-2033 period. A third (H.R. 3796) would 
affect revenues; for reasons described below, those effects are 
not included in the cost estimate.
    H.R. 1843, the Telehealth Expansion Act of 2023, would 
permanently establish a safe harbor, allowing high-deductible 
health plans to provide telehealth and other remote care 
services without making participants ineligible to use health 
savings accounts. A safe-harbor provision is currently in 
effect for calendar years 2020 through 2024. Subject to certain 
limits, contributions made by an individual to a health savings 
account are deductible for income tax purposes, and 
contributions made through a cafeteria plan are excludible from 
income for both income and payroll tax purposes. JCT estimates 
that the permanent extension would reduce revenues by $5.1 
billion over the 2023-2033 period. That reduction CBO Cost 
Estimate Page 4 Health care and other legislation, as ordered 
reported by the House Committee on Ways and Means includes a 
$3.8 billion reduction in on-budget revenues and a $1.2 billion 
reduction in off-budget revenues because it would affect Social 
Security payroll tax collections.
    H.R. 3801, the Employer Reporting Improvement Act, would 
establish a six-year statute of limitations on the assessment 
of penalties for violating the employer mandate for health 
insurance coverage under current law. The change would take 
effect on January 1, 2025. The bill also would allow employers 
90 days to respond to the first letter informing them of a 
proposed assessment, and it would codify employers' right to 
file reports electronically and to report an employee's date of 
birth if a tax identification number is not available. CBO and 
JCT estimate that the bill would lead to an insignificant 
decrease in collections of penalties, thus decreasing revenues 
by less than $500,000 over the 2023-2033 period.
    H.R. 3796, a bill to provide for the extension of taxes 
funding the Airport and Airway Trust Fund and to require the 
designation of certain airports as ports of entry, would extend 
certain excise taxes related to air travel, which are dedicated 
to the Airport and Airways Trust Fund (and currently scheduled 
to expire on September 30, 2023), through September 30, 2028. 
Because the Balanced Budget and Emergency Deficit Control Act 
of 1985 requires CBO's baseline projections to incorporate the 
assumption that expiring excise taxes dedicated to trust funds 
will be extended, JCT estimates that the extension would have 
no effect on revenues relative to CBO's baseline. In its 
baseline, CBO projects that collections of those taxes will 
total about $100 billion over the 2024-2028 period--the time 
covered by the extension. The bill also would newly designate 
certain airports as ports of entry, which would affect 
discretionary spending (see ``Spending Subject to 
Appropriation'').
    Legislation With No Effect on Direct Spending or Revenues: 
CBO and JCT estimate that six bills, described below, would 
have no effect on direct spending or revenues over the 2023-
2033 period.
    H.R. 3667, the Social Security Child Protection Act of 
2023, would require SSA to issue a new Social Security number 
to a child under the age of 14 if a parent can provide evidence 
that the confidentiality of the original number has been 
compromised by loss or theft.
    H.R. 3784, the Improving Social Security's Service to 
Victims of Identity Theft Act, would require SSA to provide a 
single point of contact for a person whose Social Security 
number is misused or whose card is lost.
    H.R. 3797, the Paperwork Burden Reduction Act, would codify 
existing rules of the Department of the Treasury and provide 
additional flexibility for employers when providing information 
about health insurance coverage to employees for tax-filing 
purposes.
    H.R. 3798, the Small Business Flexibility Act, would 
require the Secretary of the Treasury to notify employers of 
the availability of tax-advantaged flexible health insurance 
benefits, with an initial focus on small businesses.
    H.R. 3799, the Custom Health Option and Individual Care 
Expense Arrangement Act (or CHOICE Arrangement Act), would 
codify a regulation that expands the use of health 
reimbursement arrangements by allowing employers to provide 
funds to employees through individual coverage health 
reimbursement arrangements. Those arrangements permit workers 
to purchase health insurance through the nongroup market rather 
than receiving coverage through traditional employment-based 
health insurance.\1\
---------------------------------------------------------------------------
    \1\See Health Reimbursement Arrangements and Other Account-Based 
Group Health Plans, 84 Fed. Reg. 28, 888 (June 20, 2019) (to be 
codified at 26 C.F.R. pts. 1 and 54; 29 C.F.R. pts. 2510 and 2590; and 
45 C.F.R. pts. 144, 146, 147, and 155).
---------------------------------------------------------------------------
    H.R. 3800, the Chronic Disease Flexible Coverage Act, would 
codify existing Internal Revenue Service guidance, which states 
that treatment of chronic diseases is considered preventive 
care. Under that guidance, high-deductible insurance plans can 
provide such coverage without making enrollees ineligible to 
participate in health savings accounts.
    Spending subject to appropriation: CBO estimates that all 
nine bills would increase spending subject to appropriation: 
two would do so by significant amounts (more than $500,000) and 
the rest would result in insignificant increases (less than 
$500,000) over the 2023-2028 period (see Table 2). Any spending 
would be subject to the availability of appropriated funds.

        TABLE 2.--ESTIMATED INCREASES IN SPENDING SUBJECT TO APPROPRIATION UNDER H.R. 3796 AND H.R. 3667
----------------------------------------------------------------------------------------------------------------
                                                              By fiscal year, millions of dollars--
                                                ----------------------------------------------------------------
                                                   2023     2024     2025     2026     2027     2028   2023-2028
----------------------------------------------------------------------------------------------------------------
H.R. 3796, a bill to provide for the extension
 of taxes funding the Airport and Airway Trust
 Fund and to require the designation of certain
 airports as ports of entry:a
    Estimated Authorization....................        0        1        1        1        1        1          5
    Estimated Outlays..........................        0        1        1        1        1        1          5
H.R. 3667, the Social Security Child Protection
 Act of 2023:
    Estimated Authorization....................        0        *        *        *        *        *          1
    Estimated Outlays..........................        0        *        *        *        *        *          1
----------------------------------------------------------------------------------------------------------------
* = between zero and $500,000. CBO estimates that increases in spending subject to appropriation would be
  between zero and $500,000 in each year and over the 2024-2028 period for the other bills in this estimate
  (H.R. 1843, H.R. 3784, H.R. 3797, H.R. 3798, H.R. 3799, H.R. 3800, and H.R. 3801).
a CBO estimates that H.R. 3796 also would have effects on direct spending (see Table 1).

    H.R. 3796, a bill to provide for the extension of taxes 
funding the Airport and Airway Trust Fund and to require the 
designation of certain airports as ports of entry, would result 
in fewer than five airports being so designated, CBO expects. 
Under current law, CBP provides customs inspections at most 
airports that are funded in part through customs user fees, 
such as immigration user fees and fees collected under COBRA. 
Other airports, where the volume of passenger or cargo traffic 
is smaller, may voluntarily pay CBP to reimburse the agency for 
providing those inspections. Airports designated as ports of 
entry under the bill would no longer be subject to the fees.
    CBO estimates that the increase in collections of customs 
user fees under the bill (see ``Direct Spending'') would not 
fully cover the cost to CBP for providing inspections and that 
implementing the bill would require the appropriation of 
additional funds to cover those costs. Under current law, the 
airports that CBO expects to be included under the bill pay CBP 
a total of $1 million each year. Accounting for anticipated for 
inflation, CBO estimates that implementing H.R. 3796 would cost 
$5 million over the 2023-2028 period.
    H.R. 3667, the Social Security Child Protection Act of 
2023, would require SSA to issue a new Social Security number 
to a child under the age of 14 if a parent can present evidence 
that the number's confidentiality was compromised because of 
loss or theft. Under current law, SSA issues new numbers only 
when a number is misused and if the misuse has caused harm. In 
2022, SSA issued 116 new numbers to children under the age of 
14. CBO expects that requests for new numbers would increase 
under the bill and that SSA would issue more numbers. 
Consequently, CBO estimates that implementing the bill would 
cost $1 million over the 2023-2028 period.
    Pay-As-You-Go considerations: The Statutory Pay-As-You-Go 
Act of 2010 establishes budget-reporting and enforcement 
procedures for legislation affecting direct spending or 
revenues. The net changes in outlays and revenues for the three 
bills that are subject to those pay-as-you-go procedures are 
shown in Table 1.
    Increase in long-term net direct spending and deficits: CBO 
estimates that none of the bills would increase net direct 
spending in any of the four consecutive 10-year periods 
beginning in 2034.
    JCT estimates that enacting H.R. 1843 would increase on-
budget deficits by more than $5 billion in at least one of the 
four consecutive 10-year periods beginning in 2034.
    JCT estimates that none of the remaining eight bills would 
increase on-budget deficits by more than $5 billion in any of 
the four consecutive 10-year periods beginning in 2034.
    Mandates: CBO and JCT have determined that the legislation 
would not impose any intergovernmental or private-sector 
mandates as defined in the Unfunded Mandates Reform Act.
    Previous CBO estimate: On June 20, 2023, CBO transmitted an 
estimate of the direct spending and revenue effects of Rules 
Committee Print 118-9 (H.R. 3799, the CHOICE Arrangement Act), 
as amended by Amendment 8 (Smith). The language in title II and 
title IV of Rules Committee Print 118-9 is the same as that in 
H.R. 3799 and H.R. 3798, respectively, and the estimated 
budgetary effects are the same.
    Estimate prepared by: Federal costs: Jeremy Crimm (customs 
fees), Noah Meyerson (Social Security), Matthew Pickford 
(Internal Revenue Service); Federal revenues: Jessica Hale, 
Emily Vreeland, Staff of the Joint Committee on Taxation; 
Mandates: Andrew Laughlin, Staff of the Joint Committee on 
Taxation.
    Estimate reviewed by: Elizabeth Cove Delisle, Chief, Income 
Security Cost Estimates Unit; Justin Humphrey, Chief, Finance, 
Housing, and Education Cost Estimates Unit; Susan Willie, 
Chief, Natural and Physical Resources Cost Estimates Unit; 
Kathleen FitzGerald, Chief, Public and Private Mandates Unit; 
Sarah Masi, Senior Adviser, Budget Analysis Division; Joshua 
Shakin, Chief, Revenue Estimating Unit; H. Samuel Papenfuss, 
Deputy Director of Budget Analysis; Chad Chirico, Director of 
Budget Analysis; John McClelland, Director of Tax Analysis.
    Estimate approved by: Phillip L. Swagel, Director, 
Congressional Budget Office.

     V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE


          A. Committee Oversight Findings and Recommendations

    With respect to clause 3(c)(1) of rule XIII of the Rules of 
the House of Representatives, the Committee made findings and 
recommendations that are reflected in this report.

        B. Statement of General Performance Goals and Objectives

    With respect to clause 3(c)(4) of rule XIII of the Rules of 
the House of Representatives, the Committee advises that the 
bill does not authorize funding, so no statement of general 
performance goals and objectives is required.

              C. Information Relating to Unfunded Mandates

    This information is provided in accordance with section 423 
of the Unfunded Mandates Reform Act of 1995 (Pub. L. No. 104-
4).
    The Committee has determined that the bill does not contain 
Federal mandates on the private sector. The Committee has 
determined that the bill does not impose a Federal 
intergovernmental mandate on State, local, or tribal 
governments.

  D. Congressional Earmarks, Limited Tax Benefits, and Limited Tariff 
                                Benefits

    With respect to clause 9 of rule XXI of the Rules of the 
House of Representatives, the Committee has carefully reviewed 
the provisions of the bill, and states that the provisions of 
the bill do not contain any congressional earmarks, limited tax 
benefits, or limited tariff benefits within the meaning of the 
rule.

                       E. Tax Complexity Analysis

    Pursuant to clause 3(h)(1) of rule XIII of the Rules of the 
House of Representatives, the staff of the Joint Committee on 
Taxation has determined that a complexity analysis is not 
required under section 4022(b) of the IRS Reform Act because 
the bill contains no provisions that amend the Internal Revenue 
Code of 1986 and that have ``widespread applicability'' to 
individuals or small businesses, within the meaning of the 
rule.

                   F. Duplication of Federal Programs

    In compliance with clause 3(c)(5) of Rule XIII of the Rules 
of the House of Representatives, the Committee states that no 
provision of the bill establishes or reauthorizes: (1) a 
program of the Federal Government known to be duplicative of 
another Federal program; (2) a program included in any report 
from the Government Accountability Office to Congress pursuant 
to section 21 of Public Law 111-139; or (3) a program related 
to a program identified in the most recent Catalog of Federal 
Domestic Assistance, published pursuant to the Federal Program 
Information Act (Pub. L. No. 95-220, as amended by Pub. L. No. 
98-169).

       VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED


      A. Changes in Existing Law Proposed by the Bill, as Reported

    With respect to the requirement of clause 3 of rule XIII of 
the Rules of the House of Representatives, the bill, as 
reported, does not propose to repeal or amend a statute or part 
thereof.

                         VII. DISSENTING VIEWS

    H.R. 3800 (Rep. Wenstrup, R-OH; Rep. Blumenauer, D-OR) 
would codify the 2019 United States Department of the Treasury 
(Treasury) guidance relating to the section 223 of the Internal 
Revenue Code (IRC) safe harbor for the provision of specified 
low-cost chronic care services under the deductible in high 
deductible health plans (HDHPs). This bill would codify the 14 
specific preventive services described in the Treasury guidance 
as allowable under the deductible without impacting the health 
savings account (HSA) eligibility of such HDHP plan.
    Democrats have advanced laws to improve access to 
preventive care. Democrats have long championed efforts to 
ensure Americans can gain access to the care that they need at 
an affordable cost. The Affordable Care Act (ACA) guarantees 
access to copay-free preventive services across all types of 
comprehensive insurance coverage, benefitting nearly 152 
million Americans. Republicans, on the other hand, have worked 
to repeal the ACA and, failing that, have used litigation to 
unravel the ACA. Specifically, Republican initiatives are 
challenging the ACA preventive care protections for millions of 
Americans in court. It is no surprise however, that while 
Republicans claim they now support preventive benefits, it is 
only in the guise of furthering HSAs as retirement--not 
health--vehicles.
    HDHPs and HSAs are not the solution. Studies have 
repeatedly demonstrated that high out-of-pocket costs imposed 
by HDHPs result in consumers delaying or neglecting necessary 
care, rather than heightening access to care. In fact, 
according to a Commonwealth Fund study, nearly 45 percent of 
adults with high out-of-pocket expenses push off or forgo 
health care services altogether. HDHP enrollees even forgo 
needed preventive screenings that are at no-cost under the 
Affordable Care Act. By attempting to add additional services 
covered under the deductible for HDHPs, individuals might be 
further incentivized to enroll in a plan that ultimately 
provides insufficient coverage and abstain from needed medical 
care.
    HDHPs and HSAs are a wealth, rather than a health, vehicle. 
Republicans claim that HDHPs allow consumers to be smarter 
shoppers in the health care market. This, in practice, is not 
the case. A study of health care price transparency in New 
Hampshire found small decreases in costs in the short term that 
were erased in the long term.\1\ Another study found that when 
large employers provide transparent costs to their employees, 
there were no costs savings, even when those employees had 
HDHPs.
---------------------------------------------------------------------------
    \1\Glied S. Price Transparency--Promise and Peril. JAMA. 
2021;325(15):1496-1497. doi:10.1001/jama.2021.4640.
---------------------------------------------------------------------------
    Furthermore, such flexibility is only granted for the 
wealthy, who can afford to pay high health care costs out of 
pocket and who have the means to contribute to future health 
care expenses by means of HSAs. Meanwhile, middle-income or 
uninsured Americans cannot afford to cover high out-of-pocket 
costs, with half of Americans being unable to afford an 
unexpected $500 medical bill, and with Black, Hispanic, and 
female Americans as more likely not to be able to afford the 
bill. Adding the option for coverage of additional items pre-
deductible merely reduces the number of qualified expenses that 
HSAs can be used for, making them more of a retirement vehicle 
than a health vehicle.
    Expanded safe harbors for HSAs is part of a coordinated 
approach to promote these tax shelters for the wealthy. This is 
merely one of many bills that Republicans have brought forth to 
expand or codify pre-existing safe harbors under section 
223(c)(2)(c) of the IRC to allow for additional services 
covered pre-deductible for HDHPs, and it is part of a 
coordinated strategy to make HSAs more attractive as retirement 
vehicles.
    This bill ultimately will benefit the wealthiest among us, 
by eliminating services that individuals have to spend their 
HSA balances on, and instead augmenting the amount of triple 
tax preferred savings they can contribute to non-health 
expenses.

                                           Richard E. Neal,
                                                    Ranking Member.

                           SUPPLEMENTAL VIEWS

    One of the key challenges in reforming the health care 
system is finding solutions that lower the cost of health care 
while improving patients' health. I don't believe we need to 
necessarily spend more on health care but spend it more wisely 
to make the correct investments in prevention. 6 in 10 adults 
in America struggle with chronic disease and chronic disease is 
the leading cause of disease and disability in the United 
States. Preventive care services could save over 100,000 lives 
every year. Making investments in preventive care can lower our 
health care spending--something we're going to have to take on 
if we want to be serious about lowering the deficit.
    This bipartisan legislation takes aim at that by codifying 
an IRS guidance that expands the safe harbor for high 
deductible health plans to 14 preventive care services. These 
are services that are shown to be low-cost, high value services 
that will prevent the exacerbation of chronic conditions. These 
conditions are manageable, and we should be taking every 
opportunity to structure our insurance plans in a way that 
increase prevention and management.
    I understand and welcome a discussion about the role of 
health savings accounts in our health care system. But the fact 
of the matter is that more and more employers are electing to 
offer this type of coverage and we should be making sure that 
they work as well as they can. And I would welcome the 
opportunity to make sure we're improving coverage of chronic 
disease services across our health care system and especially 
in our federal programs. I urge my colleagues to support this 
bipartisan legislation.

                                                   Earl Blumenauer.