Policy Frameworks & Position Papers
Formal Pegasus work products that organize policy problems, market mechanics, regulatory structures, and practical reform concepts into reusable frameworks, proposals, and institutional analysis.
Formal work products
This page houses policy frameworks, position papers, legislative concepts, regulatory analyses, compliance frameworks, and structured proposals designed to support deeper review by policymakers, market stakeholders, researchers, and institutional partners.
Premium Subsidy Modernization
A structured proposal examining whether ACA subsidy administration could be improved by shifting from IRS-managed tax credit reconciliation toward HHS-administered advance subsidy mechanics, with a focus on affordability, program integrity, budget transparency, and consumer stability.
Transfers administration of APTC from IRS to HHS
Enables prior-year income verification for self-employed households
Supports real-time eligibility without tax filing penalties
Improves reconciliation accuracy and reduces improper payments
Small Employer Relief and Alignment
A policy concept examining whether ACA employer mandate thresholds could be better aligned with small group market definitions to reduce compliance friction, support responsible employer growth, and improve compatibility with reimbursement-based coverage models.
Examines alignment between employer mandate thresholds and small group market definitions
Creates consistency with state small group market rules
Encourages ICHRA adoption among small-to-midsize employers
Reduces administrative burden and compliance risk for growing businesses
ICHRA Salary Reduction Fairness
A policy concept exploring whether Section 125 could be updated to allow pre-tax salary reduction for Marketplace premiums when an employee opts out of APTC and enrolls through an exchange under an ICHRA framework.
Explores a Section 125 carveout to support ICHRA salary reduction
Requires APTC opt-out to avoid double benefit
Aligns tax treatment for on-exchange and off-exchange enrollees
Supports employee plan choice with clearer tax treatment
Local Access Health Reimbursement Arrangement (LAHRA)
An exploratory framework for a supplemental health reimbursement arrangement designed to help large employers address regional access gaps, narrow networks, travel-for-care needs, and specialty access challenges when using reimbursement-based coverage models.
Designed for large employers offering ICHRA in underserved regions
Provides a capped, employer-funded account to supplement ACA Marketplace plans
Addresses wraparound needs such as out-of-network care, travel expenses, or specialty access
Uses defined funding limits to manage fiscal risk and compliance boundaries
ICHRA Wrap Network Accessibility
An exploratory concept for employer-funded wrap benefits that could help address network adequacy and specialty access gaps for employees enrolled in individual market plans through an ICHRA.
Creates a framework for employer-funded wrap benefits
Expands access options for employees in network-inadequate regions
Supports emergency and specialty care gap analysis
Examines compatibility with individual market coverage and traditional group plan alternatives
Selected media references, source materials, regulatory engagement, and historical policy work help inform Pegasus Health Institute's research agenda. Some items reflect work completed before Pegasus and are included for transparency, continuity, and context.
Insights and source materials are provided for educational and informational purposes. Prior work is included for historical and contextual reference where applicable. Inclusion does not imply endorsement, representation, retention, sponsorship, or approval unless expressly stated. These materials do not constitute legal, investment, tax, actuarial, lobbying, or pay-to-play policy access services.