Phase 3: Waves 2 & 3: working-age adults · Step 3.3

Wind down the private health insurers

Years 1–5 · State insurance commissioners; NAIC; UHADiscuss this step

Every concrete action this step requires, who is responsible, and when it happens relative to enactment.

#	Action	Owner	When	Trade-off
3.3.1	Each insurer files a run-off plan: claims for services before the switch are paid for 18 months after; reserves are held until run-off ends.	Insurers / state regulators	Year 1	An 18-month run-off ensures claims are paid but keeps insurers operating in a shrinking business.
3.3.2	Prohibit dividend payouts and buybacks until run-off reserves are certified adequate.	State regulators	Year 1+	Barring dividends protects reserves but hurts shareholders who expected payouts.
3.3.3	Nonprofit insurers (most Blue Cross Blue Shield plans): when they dissolve or convert, their assets go to charitable health foundations, as with prior Blue conversions (e.g., the California Endowment).	State AGs	Years 2–5	Sending Blue Cross assets to foundations serves the public but is resisted by Blues executives and boards.
3.3.4	Insurers may continue in supplementary insurance, workers' comp, Medicare-to-UHP integrated care organizations (as providers, not insurers), international markets, and administrative contracting for UHA.	Insurers	Year 1+	Letting insurers pivot to supplementary and ICO roles preserves some jobs but keeps them in the health system with incentives to lobby for expansion.
3.3.5	Pharmacy benefit managers: contracts end; PBM-owned pharmacies keep dispensing under UHA dispensing fees.	UHA	Day 1 of each wave	Ending PBM contracts saves money but disrupts specialty pharmacy arrangements patients rely on.
3.3.6	Broker licenses for health insurance lapse; brokers may sell supplementary and other lines.	State regulators	Year 4	Letting broker licenses lapse is clean but ends an occupation for tens of thousands of people.