The Affordable Care Act Exchanges Mid-Year Summary and Assessment

SPECIAL COMMENT

INSURANCE SEPTEMBER 9, 2014

Table of Contents:

SUMMARY OPINION 1 1. WHAT WE DO KNOW – PROFITABILITY WILL BE CHALLENGING DESPITE HIGHER THAN EXPECTED ENROLLMENT 2 2. WHAT WE DON’T KNOW YET – DEVELOPING 2014 CLAIM EXPERIENCE, UNCERTAIN CONSUMER BEHAVIOR IN 2015 4 3. CHANGES FOR 2015 – AUTOMATIC RE-ENROLLMENT PROCESS AND START OF EMPLOYER MANDATE 6 4. INSURERS’ PLANS FOR 2015 – EXPANSION BEING TOUTED BUT PLANS ARE RELATIVELY MODEST 7 APPENDIX 9 MOODY’S RELATED RESEARCH 10

Analyst Contacts:

NEW YORK +1.212.553.1653

Stephen Zaharuk +1.212.553.1634 Senior Vice President stephen.zaharuk@moodys.com

Joel Levine +1.212.553.3871 Associate Managing Director joel.levine@moodys.com

Robert L. Riegel +1.212.553.4663 Managing Director robert.riegel@moodys.com

The Affordable Care Act Public Exchanges – Mid-Year Summary and Assessment

Summary Opinion

Last year as we approached the first open enrollment period under the Affordable Care Act (ACA) health insurers were faced with many unknowns and uncertainties regarding competition, enrollment, and profitability. Almost one year after the federal and state exchanges opened for enrollment many of these uncertainties still exist. In this report we examine what we do know and the challenges insurers are faced with as they prepare for the upcoming 2015 enrollment period, including the uncertainties that remain and the impact of changes scheduled to be implemented. In each instance we gauge the potential credit impact for health insurers. Our key findings are:

» The ACA individual health policies sold on and off the exchanges involve considerable risks and uncertainties and the prospects for profitability will remain challenging for several years. However, for Moody’s rated health insurers, there is unlikely to be an overall impact to their credit profile given the fact that this business makes up a relatively small portion of any one insurer’s total business.

» Due to remaining uncertainties and unresolved issues with respect to the profitability of these products, consumer behavior, and the legal status of subsidies, insurers are faced with making pricing decisions for 2015 with very limited claims data in 2014 in a competitive marketplace ripe for irrational pricing amid an evolving regulatory environment – a credit negative to the sector.

» While the planned changes for 2015 – automatic re-enrollment for most individuals and the start of the employer mandate – appear to be credit positive on the surface, we believe the actual credit implications for insurers are neutral.

» Despite all the uncertainties and poor projected financial results for these products in 2014, insurers are planning on continuing their participation on the exchanges in 2015. However, for many of the larger health insurers expansion plans are relatively modest.

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SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

1. What We Do Know – Profitability Will Be Challenging Despite Higher Than Expected Enrollment. Overall Credit Profile Of Larger Insurers Not Likely To Be Impacted

A. Enrollment

Despite lowered expectations from the start of the open enrollment period due to technical problems with the healthcare.gov website, enrollment exceeded official projections with the Obama Administration reporting over 8 million enrolled by the end of March 2014. While not every insurer has publicly reported the number of individuals enrolled in their plans, the following is a list of six large health insurance companies rated by Moody’s that have reported enrolled membership. While the enrollment for these six insurers accounts for over 30% of total ACA enrollment, this business segment comprises a relatively small portion of their total medical membership.

EXHIBIT 1

ACA Enrollment by Insurer

Insurance Financial Strength (IFS)

Rating and outlook ACA Indidvidual Membership

June 30, 2014 Percent of Total

Medical Membership

WellPoint A2, stable 769,000 2.4%

Humana A3, stable 615,000 6.3%

Aetna A2, stable 600,000 2.6%

Health Net Baa3, positive 313,000 5.4%

Cigna A2, positive 150,000 1.1%

Centene Baa2, stable 75,700 2.4%

Source: Company Filings and Transcripts

B. Demographics

Beyond the actual number of members, more critical to insurers are the demographics and health status of these members relative to their pricing assumptions. Since a large percentage of these members enrolled near or at the end of the open enrollment period at the end of March, resulting in their insurance coverage not beginning until May, insurers do not yet have enough information to assess the overall health status of the group. However, some information is emerging:

i. Health Status – Trending Credit Negative For Insurers: In June, results from a survey conducted by The Kaiser Family Foundation1 suggests that individuals in new, ACA-compliant plans are somewhat sicker than those previously covered in the non-group market. The survey also found that nearly six in 10 of those now covered by exchange plans were uninsured prior to signing up. Additionally, a recent Wall Street Journal article2 reported that newly insured patients under the ACA this year were using health services at hospitals more frequently than did the general population last year. These results are in line with initial reporting from insurers that this business will likely generate losses in 2014 as a result of higher than expected medical loss ratios.

1 The Kaiser Family Foundation (KFF) Survey of Non-Group Health Insurance Enrollees; June 2014 2 Hospitals Cash In on the Newly Insured, Wall Street Journal; August 4, 2014

This publication does not announce a credit rating action. For any credit ratings referenced in this publication, please see the ratings tab on the issuer/entity page on www.moodys.com for the most updated credit rating action information and rating history.

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SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

ii. Average Age – Late Enrollment Surge Of Younger Individuals A Credit Positive For Insurers: A June Gallup survey3 found that 29% of health insurance purchases on the exchanges were in the 18 to 29 age bracket. This compares favorably to the national percentage of 18 to 29 year olds (26%) in the total population of adults under age 65 (i.e., not eligible for Medicare). Although age is not a perfect gauge of health status, a younger insured population is generally believed to be healthier and have fewer medical care needs.

iii. Percentage Dependent On Subsidies – May Be A Credit Negative With Respect To Health Status: A report by the Henry J. Kaiser Family Foundation4 reported that through February 2014 approximately 83% of all enrollees nationwide had qualified for a subsidy. Again, while not a substitute for the actual health status of a population, this finding indicates that a majority of insureds were in low enough income brackets, and therefore there is a greater likelihood that many of these individuals were previously uninsured or may have not been receiving proper medical care. The implication for insurers is that health costs for this group may be higher than the costs for the general population. On the positive side, the fact that government subsidies are paying for a substantial portion of an individual’s premium may result in a higher retention rate among these policyholders.

C. Insurers’ Profitability Outlook On Business Dependent On The ‘Three Rs’5: As of the end of the second quarter of 2014, insurers were not painting a very rosy picture with respect to the profitability of their health exchange insurance policies. At best, insurers were predicting a break even scenario but most were anticipating losing money on the business for the full year. In addition, most insurers were relying on the financial protections built into the ACA – the ‘three Rs’ of reinsurance, risk adjustment, and the risk corridor. While there is some degree of accuracy in projecting contributions from the reinsurance arm of the three Rs, the other two remain highly uncertain and rely on assumptions with regards to the experience and results of the entire sector.

D. Credit Implications: From what we know, this business involves considerable risks and for many insurers is likely to be unprofitable or near break even for several years. The analysis that leads us to this conclusion is as follows:

» First, the risk pool has been compromised by provisions in the ACA and other provisions added or changed since the law was enacted which allow many individuals to avoid purchasing policies on the exchanges. These include exemptions from financial penalties and the ability to retain non-ACA compliant health plans.

» Second, in addition to the fact that two of the three Rs (reinsurance and risk corridor) are temporary, their stability from both a political and financial perspective is uncertain.

» And third, as premiums increase, a trend we are seeing with the 2015 plan submissions, it is likely that some of the younger, healthier individuals who purchased policies on the exchanges may drop coverage, resulting in an even less favorable risk pool.

While we understand the strategy for insurers to participate in this business for both business and political reasons, from a credit perspective we see this business as having overall negative credit implications, impacting both an insurer’s risk profile and profitability. However, given the fact that currently this business makes up a relatively small portion of the analyzed insurers’ total business, their overall credit ratings are unlikely to be impacted by this alone.

3 Gallup Daily Tracking; April 15 - June 17, 2014 4 How Much Financial Assistance Are People Receiving Under the Affordable Care Act?; The Henry J. Kaiser Family Foundation; March 2014 5 See Appendix

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SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

2. What We Don’t Know Yet – Developing 2014 Claim Experience, Uncertain Consumer Behavior In 2015, And An Unsettled Legal And Regulatory Environment Present Formidable Challenges For Insurers And Credit Negative Implications

A. Financial Results, How Bad Will They Be?

As of 30 June 2014, insurers are not indicating good financial news from the policies they sold on the healthcare exchanges. Most are reporting that they will lose money even with the potential payment of funds from the government from the three Rs. However, the insurers are not providing specific details and we cannot be quite sure what assumptions they have made regarding premiums and medical claims for the remainder of the year. As discussed below, the lapse rate on these policies could be higher than the historical lapse rates experienced on individual health insurance policies in the past. With many policies not becoming effective until April or May this year, limited data is available and there is the potential for higher than expected medical claims as well. Lastly, we have to be skeptical with respect to any assumptions about risk adjustments and risk corridor payments as these rely on a company’s experience in relation to the entire sector’s experience. Based on the anecdotal evidence at hand, we expect that results will be worse for 2014 than currently reported.

B. Consumer Behavior With Respect To:

i. Retention/Lapse Rate: A major concern with respect to 2014 enrollment is how many of the reported 8 million enrollees will retain their coverage for the full year. While lapse rates have typically been high for individual health polices in the past due to an individual’s personal circumstances changing and healthcare insurance becoming available from another source (e.g., employer or government sponsored), no one is sure what other factors will impact how this current group of enrollees behaves. As an example, Aetna, which initially reported 720,000 enrollees, reported only 600,000 remaining at the end of June, and is expecting that number to decline to 500,000 by the end of the year. The concern is especially acute for the reported 29% of policies purchased by those in the 18 to 29 age group. The risk is that as the monthly premium bills become a financial annoyance, especially for those not receiving a premium subsidy, and as individuals realize they will be unlikely to meet the high policy deductibles, many will lapse their polices before the end of the year. Those most likely to fall into this group are healthier individuals who are less likely to need medical care or insurance. This would, of course, be a major concern to insurers as this would result in a smaller and unhealthier remaining insured population.

ii. Re-Enrollment: In addition to lapse rates, insurers are concerned about how many of their current enrollees they can re-sign for 2015. By the end of the year, insurers will have made a significant investment in some of these individuals, assessing their health status and paying significant medical and pharmacy bills to stabilize their conditions. If these individuals switch carriers, the benefits of this administrative and medical spending will be reaped by the new insurer.

There are a number of issues that are unique and complicating to the re-enrollment process for these policies that makes it very difficult to predict based on experience from prior years. These include:

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SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

1) Uneven premium increases by insurance plans. With a majority of enrollees relying on subsidies to pay for their premiums, we suspect many enrollees will choose their 2015 policy based on their net cost, which may result in them switching plans. Due to the complicated subsidy formula, which is based on the premium for the second lowest priced silver plan in a region, individuals may find the ultimate net cost for their current plan being significantly higher even if the insurer did not increase premiums.

2) Consumers will be more educated and will choose policies that better meet their needs. For example, many enrollees were dismayed to find that their doctor or local hospital was not included in the plan they chose for 2014. We suspect that many enrollees will switch plans based on the provider networks available to them.

3) Problems with the website. While no one expects a reoccurrence of the problems encountered last year, some problems are expected, especially since the enrollment period is shorter this time around (November 15th through January 15th), which could complicate matters. This means all 8 million or so enrollees need to return to the website to re-enroll along with another expected 5 million new enrollees during a two month period compared to the six month window provided last year. While the Administration has proposed an automatic re-enrollment process, it has shortcomings (see discussion below), which may result in many enrollees returning to the website to choose their policies.

C. Unsettled Court Decision On Federal Subsidies: On 22 July 2014, the D.C. Circuit Court of Appeals ruled in Halbig v. Burwell that the ACA does not permit the Internal Revenue Service to subsidize individuals who bought health insurance on federal exchanges. Although the D.C. Circuit Court has decided to rehear the case, it may ultimately be decided by the Supreme Court. Should the original ruling be upheld, it would threaten the status of in-force policies sold through the federal exchange. According to the US Department of Health and Human Services (HHS), of the 8 million individuals who bought insurance under the ACA, nearly 5.4 million did so through the federal exchange, and nearly 86% of those 5.4 million, or 4.6 million, received a subsidy.

Without a subsidy, lapses among these 4.6 million policies would likely increase because policyholders may no longer be willing or able to afford the policy premiums without the financial assistance that the premium subsidies provide.

The resulting uncertainty could cause insurers to rethink their expansion and pricing strategies for the 2015 open enrollment period. While most insurers have already submitted their plans and premium rates for 2015, the implications of the original ruling change the calculus regarding insurers’ marketing and pricing assumptions. If subsidies are no longer available in the states that plan to rely on the federal exchange in 2015, the profile of the potential insurance purchaser in these states would drastically change. Under a no-subsidy scenario, insurers expect the federal exchange would attract a less healthy population because only those who most need insurance coverage would likely purchase an unsubsidized health plan. As a result, insurers have indicated that if the ruling were upheld, it would lead to higher premiums.

D. Credit Implications: The complications for insurers with the unknowns related to the ACA policies is that they will remain unknowns for another several months and some information or issues may not be resolved well into the 2015 policy year. In the meantime, insurers will need to submit initial plans and pricing for 2015 and make their final decisions with respect to their plan offerings by the end of September. Due to the financial, consumer behavior, and legal uncertainties, these polices have credit negative implications

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SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

for insurers as they are forced to make pricing decisions with very limited data in a competitive marketplace ripe for irrational pricing and in an evolving regulatory environment.

3. Changes For 2015 – Automatic Re-Enrollment Process And Start Of Employer Mandate Complicate Matters But Appear To Be Credit Neutral For Insurers

A. 2015 proposed enrollment process:

HHS has proposed that insured individuals who purchased policies on the federal health exchanges and who are receiving premium subsidies be automatically enrolled in the same plan in 2015 unless they elect otherwise. The catch is that individuals who automatically enroll will receive the same dollar subsidy they received in 2014, with a true up accounting included as part of their 2015 tax filing. There are two problems with this for individuals:

1) Because their subsidy is locked in at the same dollar amount they received in 2014, they will have to pay any monthly premium increase made by the insurance company. While individuals may ultimately receive a refund of some of these premium dollars if they were entitled to a larger subsidy, they will have to wait until they file their taxes in 2016 to receive this refund.

2) Due to the complexities of the premium subsidy formula, the changes in relative pricing among insurers, and the potential entry of new insurers, the plan that provided the lowest net premium cost in 2014 might not be the lowest net cost plan in 2015. This second point is crucial as HHS data indicates that a majority of federal exchange enrollees chose the lowest cost plans available to them.

While on paper an auto-enrollment provision may appear to be beneficial to insurers to maintain the individuals they enrolled in 2014, the economics for individuals may force them to shop for new plans on the website anyway.

B. Partial Implementation Of Employer Mandate – Employer Groups Of 100 Or More - 70% Of Employees Must Be Provided Affordable Coverage:

The employer mandate, originally set to begin in 2014, was delayed until 2015 and then it will be only partially implemented. As originally developed, the employer mandate required that all businesses with over 50 full-time equivalent (FTE) employees provide affordable health insurance for their full-time employees, or pay a penalty or fee for each employee not covered. Instead, starting in 2015, the employer mandate will only require employers with more than 100 FTEs to cover 70% of their full-time employees. The annual fee is $2,000 per employee if this requirement is not met (the first 30 full-time employees are exempt).

Initially, a concern for insurers was that their large employer health business segment would be under pressure as a result of the employer mandate. The concern was that employers would drop their employer provided health plans and opt instead to pay the relatively small penalty compared to the portion of healthcare premium required to meet the mandate. This concern has not been borne out for a number of reasons, primarily because employers were not ready to “dump” their employees into an untested public exchange. We do not see any change in this trend after the troubled rollout in 2014 along with a number of concerns regarding exchange policies (e.g., high deductibles and narrow networks). As a result, we don’t think the start of this limited version of the employer mandate will have any significant impact on insurers for 2015.

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SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

On the flip side, we do not see much potential for employers who do not meet the mandate requirements to begin providing insurance for their employees in 2015. In fact, most employers already are providing health benefits to their employees. In 2013, 91% of employers with 50 to 199 employees provided healthcare benefits. For employers with 200 or more employees, that percentage was 99%6.

C. Credit Implications:

The credit implications from the exchange auto-enrollment and the employer mandate are neutral.

Early on, the auto-enrollment process might have appeared to be a credit positive for insurers that were able to enroll a sizable number of individuals this year, but credit negative for insurers that were planning to jump into the exchange market for the first time in 2015. However, while consumer behavior in this marketplace is difficult to predict, the data indicates a very price sensitive population and we are not convinced the auto-enrollment process will yield much in benefits to the established insurers.

Due to the uncertainties that still linger concerning the public exchanges, we do not see employers dropping their group health coverage and forcing their employees to buy exchange policies in 2015. In addition, since most employers are already providing health insurance for their employees, we do not see a significant opportunity for additional growth. Therefore, we see no appreciable change in employer-provided coverage in 2015 as a result of the partial implementation of the employer mandate.

4. Insurers’ Plans For 2015 – Expansion Being Touted But Plans Are Relatively Modest

Despite the enrollment success the following six insurers had on the exchanges, plans for expansion are fairly modest. For some insurers, such as WellPoint, they are already offering plans in all their markets. For others, such as Aetna, their limited expansion plans reflect the continued uncertainties and risks associated with this business.

EXHIBIT 2

ACA Modest Expansion Plans by Insurer

Insurer 2015 Announced Plans

WellPoint No announced expansion plans

Humana No announced expansion plans

Aetna Expanding into 1 additional state

Health Net No announced expansion plans

Cigna Expanding into 3 additional states

Centene No announced expansion plans

Source: Company Filings and Transcripts

6 Employer Health Benefits, 2013 Annual Survey, The Kaiser Family Foundation, August 2013

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SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

The exception is UnitedHealth Group Incorporated, which has applied to sell plans in 24 states. In 2014 the company participated on exchanges in only four states taking a very conservative approach for the first open enrollment period, waiting to see how the market developed before it jumped in.

It should be noted that insurers can change their plans for participation on any of the exchanges. Late in 2013, some insurers pulled their applications in the last month before open enrollment due to pricing and other competitive considerations. We expect we may see similar actions this year as insurers have their submitted premiums adjusted by regulators, reassess the competitive landscape, and have better insight into the developing financial experience of policies sold in 2014.

Balancing the Opportunities vs. Risks

Over the next few years, insurers will be balancing the pros for continuing their participation on the exchanges: 1) revenue increase from new business, 2) knowledge gained from participating in the marketplace, 3) potential to be seen as an advocate allowing them to work with the Administration and influence changes; vs. the financial losses that will probably be absorbed for the next several years.

INSURANCE

9 SEPTEMBER 9, 2014

SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

Appendix

The three Rs of the ACA - Reinsurance, Risk Adjustment, and Risk Corridor

Due to the expected influx of a significant number of previously uninsured individuals into the new health insurance exchanges, the ACA contains provisions to mitigate some of the financial risks insurers are absorbing by insuring this population. These provisions – commonly referred to as the three Rs – are risk stabilization programs intended to protect insurers against the negative effects of adverse selection and risk selection in the initial years of the rollout of the individual mandate. Brief summaries of the three programs are provided below.

Reinsurance – This program is temporary and is applicable for calendar years 2014 through 2016 only. Reinsurance provides a safeguard against individuals with high medical costs. All non-grandfathered plans on the individual market, both inside and outside the exchanges, are eligible for reinsurance payments. For 2014, a health plan becomes eligible for reinsurance payments when an enrollee reaches medical costs of $45,000 (the attachment point). Reinsurance payments stop when an individual’s medical claims reach a cap, which is $250,000. The federal government will reimburse the plan for at least 80 percent of the claims cost between the attachment point and the cap in 2014. The reinsurance program is funded through fees levied on all health insurance plans, including self-insured plans that use a third-party administrator. Each insurer’s portion is calculated based on their enrollment and translates to $63 per person for the 2014 benefit year. The funds available for reinsurance payments are expected to total $10 billion in 2014.

Risk Adjustment – This program is the only one of the three programs that is intended to remain permanently in place. This program applies to individual and small group business sold on and off the public exchanges. It requires a measurement of the relative health status of an insurer’s pool of insured enrollees in each market. The program requires a transfer of funds from insurers whose pools have lower than average risk scores to insurers whose pools have a greater than average risk score. The program is revenue neutral.

Risk Corridor - The risk corridor program is a temporary program from 2014-2016 intended to share gains and losses between plans and the federal government. The risk corridor program applies only to qualified health plans in the individual and small group markets. This program requires each insurer to calculate their Allowable Costs as well as a Target Amount. Allowable Costs is the sum of medical claims and money spent on quality improvements. The Target Amount is equal to premiums collected minus a limited percentage of administrative costs. The Risk Corridor Ratio is then derived by dividing the Allowable Cost by the Target Amount.

For 2014, if the Risk Corridor Ratio is below 97%, the insurance issuer must share a portion of their profit with HHS. However, if the Risk Corridor Ratio is above 103%, the insurer will be eligible to recover some of that loss. The risk corridor program was intended to be revenue neutral with transfers from profitable insurers matching payments to insurers with losses.

INSURANCE

10 SEPTEMBER 9, 2014

SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

Moody’s Related Research

Rating Methodology:

» Moody’s Rating Methodology for U.S. Health Insurance Companies, May 2011 (133040)

Industry Outlook:

» US Healthcare Insurers: Outlook Changed to Negative from Stable, January 2014 (163188)

Credit Focus:

» Medicare Advantage Cuts: Prognosis Not Bad For Most Health Insurers, July 2014 (173285)

Special Comments:

» Q4 2013 Insurance CDS Spreads Tighten: US Health Insurers in Focus, February 2014 (163370)

» US Healthcare Insurance - Industry Scorecard, November 2013 (160573)

Issuer Comments:

» Highmark Transition Agreement with UPMC is Credit Positive, July 2014 (172580)

» Aetna’s Health Insurance ‘CAT’ Bonds Provide Limited Risk Protection, January 2014 (163362)

Sector Comments:

» Affordable Care Act Policies’ Automatic Renewal is a Mixed Bag for US Health Insurers, July 2014 (172579)

» US Health Insurers’ Proposed Rate Increases on Affordable Care Exchanges Are Credit Positive, June 2014 (172148)

» Final Medicare Rates for 2015 Are Credit Negative for US Health Insurers, April 2014 (168032)

» Affordable Care Act Open Enrollment Extension Is Credit Negative for Insurers, March 2014 (166679)

» US Affordable Care Act Extension Is Credit Negative for Healthcare Insurers, March 2014 (165841)

» US Health Insurers See Credit-Negative 2015 Preliminary Medicare Rates, February 2014 (165451)

» Medicare Advantage Enrollment Results are Credit Positive for Health Insurers, February 2014 (165295)

» Proposed Changes to Affordable Care Act Are Credit Negative for Health Insurers, February 2014 (164978)

» Preliminary US Healthcare Exchange Demographics Are Credit Negative for Health Insurers, January 2014 (162822)

» US Health Insurers Get Dose of Complexity and Risk from New Requirements, December 2013 (161799)

» Affordable Care Act Changes Are Credit Negative for US Health Insurers, December 2013 (161039)

INSURANCE

11 SEPTEMBER 9, 2014

SPECIAL COMMENT: THE AFFORDABLE CARE ACT PUBLIC EXCHANGES – MID-YEAR SUMMARY AND ASSESSMENT

Report Number: 175059

Author Steve Zaharuk

Production Specialist Prabhakaran Elumalai

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