BIP Summer 2025

reduce plan choices and harm consumers. As a broker, economist, and founder of Benefit Sculptor, Kuhni has long been focused on the multitude of factors that drive costs within the health insurance market. But it wasn’t until Utah faced repeated legislative attempts to outlaw accumulator programs that he began modeling the consequences in detail. Copay accumulator programs were created in response to a workaround popularized by drug manufacturers. Facing rising out-of-pocket costs, many patients began relying on manufacturer coupons to cover their deductibles. Insurers, however, saw this practice as a way of bypassing

plan design — making low premium, high-deductible plans function like rich coverage with none of the cost-sharing accountability. “Coupons were turning bronze plans into silver or gold plans,” Kuhni says. “That fundamentally breaks actuarial assumptions, and premiums have to adjust accordingly.” The result? A white paper filled with data models, charts and plain-English explanations of how accumulator bans distort both health plan pricing and consumer behavior. After Utah’s accumulator bill failed in its fourth consecutive year — thanks in large part to coordinated advocacy fueled by Kuhni’s white paper — NABIP national took notice.

Soon after, word came from CEO Jessica Brooks-Woods that the document had made its way into other states’ hands, helping support similar advocacy across the country. Nicole Kuhni, Erick’s wife and the outgoing NABIP Utah president, helped lead the distribution effort in Utah. Together, they sent the paper to over 2,500 clients, legislators and business leaders. “We were literally on the steps of the Library of Congress during CapCon when we got the call,” Nicole recalls. “Erick’s paper squashed the bill.” With more states likely to face similar legislation in the coming year, Kuhni’s work is positioned to remain a critical tool in NABIP’s advocacy arsenal.

TIP: Kuhni suggests redirecting copay assistance funds toward premium or cost-sharing subsidies — or, more radically: “Drug companies … could … just charge less.”

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