Nevada Health Care Future Submits Public Comment on 1332 Waiver

CARSON CITY, Nev. – Nevada’s Health Care Future (NVHCF) submitted a public comment for the June 15 forum, “1332 Waiver: Nevada Battle Born State Plans and Market Stabilization Program.”

Read NVHCF’s comment below:

Nevada Health Authority
Division of Consumer Health
4070 Silver Sage Drive
Carson City, NV 89701

RE: Public Comment on the 1332 Waiver – Nevada Battle Born State Plans and Market Stabilization Program

Dear Administrator Krupp and Nevada Health Authority Staff:

On behalf of Partnership for Nevada’s Health Care Future, thank you for the opportunity to submit comments for the record regarding Nevada’s Section 1332 Waiver and the Nevada Battle Born State Plans and Market Stabilization Program.

As Nevada evaluates the future of its 1332 waiver program, we urge state leaders to closely examine the disappointing performance of the Nevada public option and the significant risks it poses to the broader health care market.

The Nevada Battle Born State Plans were approved in 2021, with the expectation that the public option would achieve meaningful enrollment and market participation. However, the program has significantly underperformed since implementation in January 2026. Nevada assumed a 40 percent take-up rate in its waiver application, and the 1332 waiver expressly requires a 35 percent enrollment threshold, yet the Nevada Battle Born State Plan reportedly achieved only approximately 10 percent enrollment in 2026. This dismal enrollment rate demonstrates that most consumers have determined commercial plans are a better value for themselves and their families.

As a result, Nevada will be required under specific term and condition 11 of the waiver to provide additional premium support at the earliest feasible date and no later than December 31. This would place additional financial strain on the state while asking taxpayers to subsidize a program that consumers rejected.

Rather than continuing to prop up an unsuccessful public option program, Nevada should instead request an amendment1 that removes the public option from the state’s 1332 waiver and allows the waiver to focus solely on reinsurance and market stabilization efforts. Reinsurance programs have consistently proven more effective at lowering premiums and stabilizing insurance markets without the market disruption and administrative complexity associated with government-controlled public option plans.

Prior research conducted by subject matter experts clearly predicted what is happening today – that the public option program will harm Nevadans. NVHCF engaged Wakely Actuarial Consulting to perform a quantitative analysis2 of SB 420 in advance of the state’s revised 1332 waiver application. Wakely’s experts determined the public option would likely worsen Nevada’s already significant health care provider shortage. The state is currently ranked 48th nationally for primary care physicians per capita, and further deterioration would have devastating consequences. Additionally, the program will also put financial hardships on hospitals, further threatening access to care for patients in need.

Nevada’s experience is also consistent with what we have seen nationally: there is no successful public option program anywhere in the country. In both Washington and Colorado, public option programs have failed to meaningfully lower costs, struggled with low enrollment, reduced consumer choice, and created additional pressure on providers and insurers. Nevada should not continue down the same failed path.

Partnership for Nevada’s Health Care Future supports policies that improve affordability, expand access, and strengthen the health care system without increasing taxpayer burdens or destabilizing the private market. We encourage Nevada policymakers to focus on solutions with a proven record of success rather than continuing to invest in a public option model that has repeatedly failed to deliver on its promises.

Thank you for the opportunity to provide comments for the record.