TALKING SHOP: Revisting the Small-Business Marketplaces in California and Colorado Leif Wellington Haase David Chase Tim Gaudette President Vice President for National Outreach Colorado Outreach Manager LWH Consulting Small Business Majority Small Business Majority JULY 2017 JULY 2017 Talking SHOP: Revisiting the Small-Business Marketplaces in California and Colorado Leif Wellington Haase, David Chase, and Tim Gaudette ABSTRACT ISSUE: The Small Business Health Options Program (SHOP), established alongside the Affordable Care Act’s individual insurance marketplaces, has weathered the storms of its early implementation. But the program’s future is uncertain. GOAL: To evaluate the impact of changes to SHOP since 2014, focusing on California and Colorado—two states that run their own marketplaces and have full-featured SHOPs. METHODS: Interviews conducted with more than 50 stakeholders and policymakers, as well as employee surveys. KEY FINDINGS: Although SHOP has made modest gains in enrollment in California and Colorado, and in the many states in which it is managed by the federal government, the program still covers fewer than 150,000 people nationwide. The relative fortunes of SHOP appear closely tied to the performance of the ACA insurance exchanges for individuals and families. Though the California and Colorado programs are similar in design, California’s has had more success, largely because of its stability and the broad political acceptance of the ACA within the state. CONCLUSION: While SHOP has the potential to grow, especially if it evolves into more of a “one-stop shop” for employee benefits, the program has a long way to go if it is to become a focal point of the small- group insurance market. TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 3 INTRODUCTION and surveyed several dozen employers in these The Small Business Health Options Program states. (SHOP)—the health insurance marketplaces established under the Affordable Care Act COVERED CALIFORNIA FOR SMALL (ACA) for small employers—has weathered the BUSINESS: OVERCOMING TURBULENCE storms that marked its early implementation. California’s individual ACA marketplace However, it still faces an uncertain future, as launched relatively smoothly. Political the program covers fewer than 150,000 people opposition to the law in the state was muted, nationwide.1 and many market reforms were already in place. In California and Colorado, two states that set up their own marketplaces and began full- By contrast, the SHOP rollout was rocky. featured SHOPs in 2014, the early problems Insurance brokers complained, and those associated with the ACA—balky and unusable managing the rollout often acknowledged, that websites, delayed vendor payments, and the software and website were not tailored broker hostility—are largely a thing of the past. to small groups, that exchange staff were Moreover, another obstacle to potential unfamiliar with the commercial small-group growth has been removed in these states. market, and that agents were paid slowly or “Grandmothered” plans that were noncompliant not at all. with the ACA, and which locked up three- quarters of the small-group insurance market Since then, most of the glitches have been (usually defined as serving businesses with 50 overcome, and the number of enrollees in or fewer employees) are no longer available. SHOP almost doubled between early 2015 and July 2016, to 28,964 from 15,671, with These changes have allowed a true test of an average group size of 7.5 members.3 As the advantages that SHOP intended to bring of spring 2017, 32,684 enrollees from 4,315 to the small-group marketplace—such as employers were covered.4 employee choice, ease of administration, and affordability. (See the box below and our The problems were addressed by turning over previous report for more background on SHOP day-to-day administration and marketing and the program’s history.2) to a Southern California general agent, Pinnacle TPA; rebranding SHOP in California To evaluate the impact of these developments, as “Covered California for Small Business” we interviewed more than 50 stakeholders (CCSB); and hiring executives well versed in and policymakers in Colorado and California selling to small businesses. Brokers and general commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 4 SHOP: A BRIEF HISTORY Small businesses—those with one to 50 workers—are less likely to offer health care coverage than larger companies. Those that do offer coverage usually do not offer their employees a choice of plans, nor do they typically offer as wide a range of benefits as do larger employers. Small businesses lack the purchasing power of larger groups, have fewer workers over whom to spread the risk of high medical costs, and face higher administrative costs. Ninety-seven percent of all companies with more than 100 employees in the United States offer health insurance benefits, while only 57 percent of small businesses do. Just over 20 percent of small businesses offer two or more insurance plans, compared with more than two-thirds of companies with 50 or more employees. Under the ACA, the Small Business Health Options Program (SHOP) requires small-business marketplaces to be set up in every state alongside individual exchanges. SHOP attempts to make it easier for employers to compare health plans, and to give their employees choice in coverage at an affordable price. The Affordable Care Act (ACA) also offers an incentive to buy coverage in the form of a temporary sliding-scale tax credit, available only through plans purchased through SHOP. Like the individual marketplaces, SHOP was initially affected by hard-to-navigate websites in both the state-run and federally operated exchanges. Publicity and marketing were scant. Brokers—who handle about 80 percent of the insurance business for small employers—were wary. Most brokers encouraged small businesses to renew coverage on existing terms to avoid ACA-related changes, such as community rating and standardized benefits. Some 70 percent to 80 percent of small employers retained these so- called grandmothered plans. Thus, it was not until 2017 that most small employers in a majority of states purchased plans fully meeting ACA standards. Currently, 17 states and the District of Columbia operate their own SHOP exchanges, while the remaining SHOPs are run by the federal government (FF-SHOP). Mississippi, New Mexico, and Utah have state-run SHOPs, but their individual marketplaces are federally run. In spring 2017, the federal government reported that SHOP had enrolled 232,698 employees from 27,205 firms. Of this total, over 80 percent were enrolled through state-run SHOP programs. The number of businesses electing the tax credit has not been released.a Just as enrollment varies widely by state, so does the number of insurers participating in SHOP. Employers in Massachusetts, New York, and Oregon, for instance, can choose from eight or more insurers. But Alabama, Nebraska, North Carolina, and Tennessee have just a single insurer offering products through the small- business marketplace. a E. Curran, S. Corlette, and K. Lucia, “State-Run SHOPs: An Update Three Years Post ACA Implementation,” To the Point, The Commonwealth Fund, July 29, 2016. commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 5 agents write the policies on paper and then of these brokers are more liberal politically process them through Pinnacle, which also than the previous norm, and they have not markets SHOP as a distribution channel. This established tight relationships with insurers. arrangement appears to be working smoothly. In most cases, agents are being paid promptly. CCSB in the California Marketplace As one agent put it, “We are selling the product, Most stakeholders felt that CCSB had carved not dealing with the flubs.” out a viable niche in the marketplace or had at least bought itself enough time to do so. Brokers Come on Board One health insurance executive said: “CCSB Brokers told us that the state’s ACA marketplace, is working. … It has created the same value Covered California, is increasingly perceived proposition as other small-group exchanges, as a trusted brand. This is a turnaround from one that we know can be successful because the early implementation of SHOP, when it has been successful in the past. They are association with the ACA was far more likely making steady progress. In the context of a to induce wariness and a “wait and see” normal marketplace, they should be doing mentality. a bit better, if they hadn’t fouled up the administration.” After a slow start, brokers have been working closely as partners with Covered California. Another executive believed that the “greatest Over 14,000 brokers serve the individual struggle for Covered California is ‘carrier market, while 2,000 are certified to sell through content’ (i.e., access to specific insurers and CCSB. According to industry sources, 20 their products),” but that this disadvantage percent of brokers control 55 percent of the could be overcome. Cal Choice, the private CCSB market, while half of all brokers who marketplace competitor to CCSB, has exclusive have done business with CCSB have just one access to Anthem in the small-group market, account with the program. A small fraction, an insurer which tends to appeal to companies perhaps 200 altogether, are responsible for that want more comprehensive coverage. This writing the bulk of policies through the executive felt that if Covered California could program. One policymaker said, “Brokers are at persuade Blue Shield of California to offer the forefront of the distribution of plans in the more robust plans and a wider network than individual marketplace, and this has carried it currently offers through CCSB, then CCSB over to SHOP.” would be able to compete against Cal Choice. CCSB has found a niche, in particular, among Other analysts disputed this “glass half-full” brokers new to the business, according to an perspective. They argued that being similar experienced benefits administrator. Some to Cal Choice—the “800-pound gorilla” of commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 6 private exchanges for the small-group market of $13.95 per policy, which insurers argue may in California, run by Southern California exceed their actual net margin on the sales of general agent Word & Brown, with more than small-group plans. 180,000 covered lives—would put CCSB at a permanent competitive disadvantage and at One way insurers can meet the demand risk for failure. They also pointed to the demise for better service and less expensive CCSB of Pac Advantage, a state-run, voluntary, products will be to invest in more efficient small-employer purchasing pool, which technology. For instance, online quoting ceased operations in 2006. When early growth through Pinnacle, the general agent that petered out, carriers stopped participating, administers the program in California, began and the marketplace attracted a larger share in spring 2017. This will position CCSB to of individuals who were more expensive to compete more effectively against off-exchange insure. sales. Colorado and California are among the few states that followed the original ACA CONNECT FOR HEALTH COLORADO: GLITCHES OVERCOME, HEADWINDS PERSIST prescription to change the definition of the small-group marketplace upward to In Colorado, most stakeholders concurred with companies with one to 100 employees, from the broker who said that “the SHOP website those with one to 50 employees. While the is much better, the connectivity to carriers is increase was intended to improve the stability better, and Connect for Health Colorado has of small-group coverage inside and outside the the right people in place.” marketplaces, some analysts were concerned it could have the opposite effect.5 This reflected, After an initial, unsatisfactory rollout of in large part, employer worries about the SHOP, senior officials at Connect for Health impact of switching to ACA-compliant plans. Colorado (CFHC) brought in a broker team in However, the actual rise in premiums in the 2016 to help manage the site and make it much statewide small-group marketplace, and in easier to navigate. An official in the Colorado SHOP, have been modest—just over 3 percent Governor’s Office of Information Technology in 2016 and 2 percent in 2017 for the market as who had prior experience with the credit a whole.6 card industry led the overhaul of the website from scratch. Prior to their intervention, A jump in fees to carriers, intended to cover two different tech vendors, CGI and Deloitte, the cost of running the exchange, might also worked simultaneously on the individual slow take-up of CCSB plans. Covered California and SHOP systems. Many users of the site and has proposed increasing the assessment to 4 marketplace administrators felt this work percent of premiums, shifting from a flat fee tended to be at cross purposes. commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 7 Some dissatisfaction with the site remains. A of premium increases in the small-group Fort Collins-based broker said that “a better market, which went up a modest 2 percent in platform would yield more broker interest.” 2017. While higher premiums related to the For instance, it remains burdensome to add redefinition of the small-group market may yet an employee after the initial purchase of a materialize in the next cycle of renewals, there product through the SHOP portal. The owner is little sign of such a trend to date. of a civil engineering firm said: “Other than the choice aspect, it has been an administrative Both business owners and some advocates nightmare. Tech is kluge. Incorrect invoices for health care reform have reservations both on group plan payments and EHBs for about the ACA. While a 2016 ballot initiative employees. Emergency room declines occurred recommending a single-payer plan for saying the employee has no coverage.” Colorado failed to pass, it highlighted the difficulties the ACA faces in getting traction in In Colorado, political opposition to the Colorado. One backer of the initiative told us: ACA remains significant, skepticism among “There is a lack of momentum for Obamacare businesses persists, and turnover in the in the state. Part of what is making the ACA in insurance marketplace has created obstacles. Colorado less desirable is that companies are During the second open enrollment session finding ways to get out of it.” in the individual marketplace, enrollment actually dipped in Colorado, and it only The Connect for Health Colorado staff has partially recovered in 2016. Thanks in large been under constant pressure from the state part to the federal failure to pay promised legislature, which passed a bill increasing state risk-adjustment payments, Colorado oversight of the exchange. Legislators also HealthOP, which had covered 60,000 lives, introduced a measure, which failed, to transfer ceased operation in 2016. Although Colorado the marketplace to federal control. HealthOP did not cover small businesses, its termination had a strong ripple effect on The political pressure has stretched the exchange operations generally.7 capacity of CFHC and left it with limited options to market SHOP. Although everyone A survey of 300 Colorado small-business we interviewed wanted to expand SHOP in owners whose companies ranged in size from theory, competing priorities make this difficult. five to 100 employees, conducted in 2015 by In practice, the effort to publicize SHOP has Delta Dental, found that 61 percent of them been placed on a back burner. believed the main result of implementation of the ACA was higher costs.8 This rise, however, This, combined with business wariness and was not reflected in the most recent round lack of knowledge of SHOP, explains why commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 8 uptake in Colorado has been slow. In October Employee choice also drew kudos from several 2014, 2,521 individuals were enrolled. In 2015, Colorado brokers, especially in the eastern enrollment reached 3,314, from 472 businesses. half of the state, which tends to have more- By May 2016, that number had declined to affordable products. SHOP’s ability to offer 2,897, but it has rebounded somewhat to reach multiple carriers on multiple tiers is unique in the current high of 3,753 enrollees from 536 Colorado. One broker observed, “SHOP has a companies. mandate to offer those multiple plans. No one else can.” Another said, “I think some brokers One insurance executive remarked: “The are coming back into SHOP” who did not write exchange is fighting history and culture in policies initially. Colorado. I don’t think much about SHOP when I think about the exchange. There wasn’t In mountainous Western Colorado, which has a ton broken in the small-business market, and some of the highest rates in the country, up growth has been anemic.” to three times Denver’s rate, employee choice also drew praise. A broker in Grand Junction, noting that small nonprofits and new marijuana FINDING A NICHE businesses were in her book of business, Employee Choice said that some of her clients wanted a mix of Most owners taking the survey in both less expensive insurance products and more Colorado and California reacted positively to traditional PPO plans. She said that SHOP was SHOP’s offering of a wider choice of plans for the right vehicle to make this combination work. employees. As one Colorado employer with eight workers put it: “We like the versatility Tax Credits and choice it gives my employees. While we In our previous research, we found that many are mostly a younger group of people we all small-business owners did not know about the have different priorities it seems.” An owner of tax credit available exclusively through SHOP. a media company with 35 employees, whose Two years later, most owners who responded workers range in age from their twenties to to our more recent survey were now aware their sixties, likewise said: “SHOP allows more of the incentive, but were for the most part choice to adequately cover the age range. ineligible to take it, with one exception, Older workers buy on the relationship with because their wage structure was too high to the doctor, younger ones choose lower price qualify. mostly.” The owner of a civil engineering consulting firm, in business for 22 years, said, “I In California, one-half of the businesses highly value choice and driving the decision on covered under SHOP appear to have had no coverage down to my employees.” prior insurance coverage. In particular, small commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 9 not-for-profits seem to be electing this coverage SHOP plans, however, allow employers to and are more likely to take up the tax credit. exclude dependents from participating in their plans. With employee-only coverage, families While national surveys show that the tax credit are free to seek coverage on the individual is a primary reason small employers consider exchange and remain eligible for subsidies. SHOP, few employers actually qualify for the Broker sources indicated that as many as one- credit because of its low limit on the average quarter of CCSB plans written in California wage of a firm’s employees. For those that do, were employee-only, many reflecting the aim however, SHOP is valuable. According to a of employers to circumvent the “family glitch.” number of policymakers, expanding the length of time the credit is available and increasing Our research reflected the interest in using the average wage ceiling could prompt many SHOP to overcome this problem. A custom small businesses to take a second look. crating and shipping company with six full- time employees, based near Denver, explicitly Overcoming the “Family Glitch” made its coverage “employee only” so that the spouses and children of its workers could One unexpected way CCSB has attracted receive tax credits on the individual exchange. customers is by surmounting the “family glitch” that affects a number of workers In addition, because employers have the option covered by the ACA. of choosing a single plan for employees in and out of state or creating new SHOP accounts in This glitch was a largely unforeseen each state and offering different plans, some consequence of the way the law was drafted. brokers feel that SHOP is an easier platform Under the ACA, if one family member has an through which to cover small businesses with employer offer of single coverage that meets multistate employees. This accounts for a small the standard of affordability—costing less than but steady book of business.10 9.66 percent of family income in 2016—then all family members including the employee are ineligible for subsidies on the individual End of “Grandmothered” Plans marketplaces, even if the cost of providing Most policymakers, stakeholders, and brokers coverage to the whole family exceeds that expected that SHOP enrollment would pick percentage. Insurance plans, though nominally up once noncompliant “grandmothered” affordable, appear so only because the full plans were phased out in 2015. (California family costs of health do not count toward the and Colorado were among the handful of affordability criteria. More than six million states that followed this timetable.) While people nationwide live in such families.9 California’s enrollment almost doubled, few commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 10 experts thought this had been a principal the benefits offered by SHOP, including the tax factor, citing instead the much improved credit, are too limited. Attractive features like technology and broker comfort with the employee choice are not enough to eclipse the products, better management by the third- appeal of an off-exchange market that offers party vendor, and more successful outreach competitively priced insurance products. and rebranding. SHOP has done reasonably well attracting small firms without any history of providing THE FUTURE OF SHOP: PORTAL TO A RANGE benefits, historically the hardest to reach, and OF EMPLOYER BENEFITS? in particular small urban start-ups and not-for- The links between employment and health profits. In California and Colorado, at least, it care in the U.S. have remained strong since the has had trouble attracting, as one small-business passage of the ACA. In California, for instance, owner put it, “the non-boutique businesses, the share of companies offering employer- such as family-run mom-and-pop Laundromats, based coverage and the share of employees drugstores, and independent food stores, working at companies offering health especially in rural areas, which are not served insurance remained stable between 2013 and well by the current health care system.” 2015.11 According to a 2016 study by the insurer Aflac, millennial workers were more likely In interviews and through our survey, multiple than others to consider benefits when looking small-business owners, brokers, and other for a job and to trade off salary for benefits if stakeholders expressed the hope that a new the latter were sufficiently appealing.12 The and comprehensive approach to employer owner of a roofing company in California benefits would be taken, one promoting told us he lost eight of his twenty younger employee health through a variety of ways, and middle-aged employees to a competitor including disability insurance and financial because it offered health benefits; he signed up security instruments such as expanded 401(k)s. for SHOP and quickly found replacements. “In financing health care, you have to look The challenge small businesses face in finding beyond just health insurance,” one Colorado affordable health insurance and choice in broker said. Colorado’s exchange has in coverage still needs to be addressed. However, fact created a public benefits corporation there is no consensus that SHOP is the right with the express goal of widening the range vehicle through which to achieve these goals. A of insurance benefits SHOP can sell while Colorado-based policy analyst spoke for many remaining compliant with the law. in saying that “SHOP is trying to solve a real problem but has the wrong set of incentives Several respondents mentioned online HR to do it.” Small employers tended to feel that tools, like BerniePortal and Zenefits, as models commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 11 for the “all in one” solutions demanded by But features that may seem redundant small-business clients.13 They suggested that or rudimentary in mature small-group SHOP’s migration to an online platform would marketplaces may be crucial in less developed help it offer comparable solutions. The better ones, such as in many states that now the online platform, the better the customer participate in FF-SHOP, the federally run small- will be able to understand benefits and switch group marketplaces.14 SHOP has had early, plans easily. If SHOP can become a conduit to a full-fledged trials in places that probably need range of bundled insurance products, available its existing benefits the least. with minimum hassle, it may vault from being a niche player to a small-group-market leader. commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 12 NOTES 9 Buettgens, L. Dubay, and G. M. Kenney, “Marketplace M. K. Counihan, Update on SHOP Marketplaces for Small 1 Subsidies: Changing the ‘Family Glitch’ Reduces Family Businesses (Centers for Medicare and Medicaid Services, Health Spending But Increases Government Costs,” July 2, 2015). Health Affairs, July 2016 35(7):1167–75. W. Haase, D. Chase, and T. Gaudette, Lessons from 2 L. 10 See HealthCare.gov, SHOP Marketplace Insurance for the Small Business Health Options Program: The Multiple Locations and Businesses (CMS, n.d.). SHOP Experience in California and Colorado (The 11 L. Hartman, California Employers Continue to Offer Commonwealth Fund, Aug. 2015). Insurance, But Fewer Workers Enroll (California Health V. Lee, Executive Director’s Report (Covered California, 3 P. Care Foundation, Aug. 4, 2016). Aug. 18, 2016). 12 Aflac, 2016 Aflac WorkForces Report (Aflac, 2016). 4 Center for Consumer Information and Insurance 13 See BerniePortal, Benefits Administration and HR Oversight, “CMS Offers New Health Coverage Software (BerniePortal, n.d.). Enrollment Option for Small Business,” News release (CCIIO, May 15, 2017). 14 ee M. A. Morrissey, Health Insurance, 2nd ed. (Health S Administration Press, 2014), on the differences between American Academy of Actuaries, Potential Implications 5 state small-group health care insurance markets. As of the Small Group Definition Expanding to Employers of May 2017, the Centers for Medicare and Medicaid with 51–100 Employees (AAA, March 2015). Services (CMS) announced that as of the end of 2017 it L. Norris, Colorado Health Insurance Marketplace: 6 would no longer handle enrollment and other functions History and News of the State’s Exchange for the FF-SHOP exchange, essentially shuttering that (healthinsurance.org, June 22, 2017). wing of the SHOP program. T. Jost, “CMS Announces Plans to Effectively End the SHOP Exchange,” Health Stein, “Here’s What Happened to Colorado HealthOP,” 7 N. Affairs Blog, May 15, 2017. Colorado Independent, Oct. 23, 2015. Dano, “What’s the Word on the Affordable Care Act 8 M. Three Years In?” ColoradoBiz, June 9, 2016. commonwealthfund.org July 2017 TALKING SHOP: Revisiting the Small-Business Marketplaces in California and Colorado 13 ABOUT THE AUTHORS also served as chairman for the all-volunteer board of the Leif Wellington Haase, M.A., M.Phil., is president of Denver Gay and Lesbian Chamber of Commerce, and in LWH Consulting and a leading author and researcher 2016 was recognized by the Chamber as Business Person of on the U.S. health system, focusing on health care the Year. This year, Gaudette was appointed by Colorado’s reform, insurance coverage, and health care costs. He is insurance commissioner to the Consumer Insurance the author of numerous publications, including A New Council, where he provides insight on behalf of the small- Deal for Health: How to Cover Everyone and Get Medical business community on health insurance issues in the state. Costs Under Control, National Health Insurance: Lessons He has degrees from the College of William and Mary and from Abroad and Lessons from California’s Health the University of Exeter. Reform Efforts for the National Debate. Haase has served as executive director for the California Task Force on Affordable Care and was director of the New America Editorial support was provided by Jennifer McDonald. Foundation’s California Program, which sponsored research on issues of critical importance to California, including health care, education, energy, and tax and budget policy. Before joining New America, he served as senior program officer at The Century Foundation, leading For more information about this report, please contact: its health policy program. Haase holds degrees from Yale Leif Wellington Haase, President, LWH Consulting, at University and Princeton University. haasenewamerica.org. David Chase is vice president for national outreach at Small Business Majority, a national small-business advocacy organization focused on solving the biggest problems facing small businesses today. He works on About The Commonwealth Fund business outreach, state advocacy, and development. The Commonwealth Fund, among the first private Chase serves on the California health care exchange’s foundations started by a woman philanthropist—Anna M. Small Business Health Options Program Advisory Group Harkness—was established in 1918 with the broad charge to and directs Small Business Majority’s national health enhance the common good. care policy work. Previously, he served in the office of The mission of The Commonwealth Fund is to promote a California Governor Arnold Schwarzenegger, where he high performance health care system. The Fund carries was part of the team responsible for building the coalition out this mandate by supporting independent research on behind the governor’s 2007 bipartisan health care reform health care issues and making grants to improve health care proposal. practice and policy. An international program in health policy Tim Gaudette is Colorado outreach manager at is designed to stimulate innovative policies and practices in Small Business Majority, directing their outreach and the United States and other industrialized countries. development efforts in Colorado. He works to build and Support for this research was provided by The maintain relationships with small-business owners, Commonwealth Fund. The views presented here are organizations, and foundations. Before joining Small those of the authors and not necessarily those of The Business Majority, Gaudette worked at a small business in Commonwealth Fund or its directors, officers, or staff. Denver and his background includes significant finance and To learn more about new publications when they become investment-related work in the regulatory, research, and available, visit the Fund’s website and register to receive sales areas in Denver, Washington, D.C., and Baltimore. He email alerts. commonwealthfund.org July 2017