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The growth in health care costs in the United States in the past two decades has been staggering and extraordinarily burdensome not only to the federal and state governments but also to employers and individuals who purchase their health insurance in the private market. According to a recent report by the Urban Institute Health Policy Center, four major and interrelated reasons are the significant drivers of the persistent rise in health care costs in excess of economic growth. The first is over-insurance due to the favorable tax treatment of employer-sponsored insurance to which approximately fifty-eight percent of non-elderly Americans have access. The second is "the development and dispersion of medical technology."' The third reason is the "increasing prevalence of chronic disease," which tends to be very expensive to treat and consumes a large share of health care costs. The fourth is the consolidation and market power of health care providers and insurers. As will be discussed, the Patient Protection and Affordable Care Act ("ACA"), enacted in March 2010 but not fully implemented until 2014, addresses some of these issues and attempts to mitigate their effects, but does so incompletely. According to many health policy experts, the ACA is limited in its efforts to contain health care spending, and either does not address certain issues at all or does so insufficiently.