California

I'm not sure how this slipped by me, but in addition to Covered California already having launched their 2020 Open Enrollment Period yesterday, five other state-based ACA exchanges are already partly open as well. That is, you can shop around, compare prices on next year's health insurance policies and check and see what sort of financial assistance you may be eligible for:

I'm not sure when the other 7 state-based exchanges will launch their 2020 window shopping tools, nor do I know when HealthCare.Gov's window shopping will be open for the other 38 states, although I believe they usually do so about a week ahead of the official November 1st Open Enrollment Period launch date.

As I noted yesterday, while the 2020 Open Enrollment Period doesn't officially start until November 1st across the rest of the country, in California it already started on October 15th, two weeks earlier than everywhere else.

I also noted that there's two important points for CA residents to keep in mind starting this Open Enrollment Period:

  • First: The individual mandate penalty has been reinstated for CA residents. If you don't have qualifying coverage or receive an exemption, you'll have to pay a financial penalty when you file your taxes in 2021, and...
  • Second: California has expanded and enhanced financial subsidies for ACA exchange enrollees:

Until now, only CoveredCA enrollees earning 138-400% of the Federal Poverty Line were eligible for ACA financial assistance. Starting in 2020, however, enrollees earning 400-600% FPL may be eligible as well (around $50K - $75K/year if you're single, or $100K - $150K for a family of four). In addition, those earning 200-400% FPL will see their ACA subsidies enhanced a bit.

While the 2020 Open Enrollment Period doesn't officially start until November 1st across the rest of the country, in California it begins two weeks earlier, for whatever reason:

In most states, open enrollment for 2020 coverage will run from November 1, 2019 to December 15, 2019. But California enacted legislation (A.B.156) in late 2017 that codifies a three-month open enrollment period going forward — California will not be switching to the November 1 – December 15 open enrollment window that other states are using.

Instead, California’s open enrollment period (both on- and off-exchange) will begin each year on October 15, and will continue until January 15. Under the terms of the legislation, coverage purchased between October 15 and December 15 will be effective January 1 of the coming year, while coverage purchased between December 16 and January 15 will be effective February 1.

Normally I write two separate annual premium rate change filing entries for each state: One when the preliminary/requested rate filings are submitted, and another one when the final/approved rates are published.

In the case of California, it turns out that the rate rview/negotiation process is...more complicated. The press release/report released by Covered California back in July referred to preliminary 2020 premiums only, but it turns out that Covered California exchange personnel had already completed all their negotiations before posting any numbers.

It also turns out (thanks to "Dena M." aka @HealthEDena) that in California, insurance policy premiums are not reviewed/approved by the state insurance department...but by an entirely different department called the Dept. of Managed Health Care, or DMHC.

*(Yes, I know, the District of Columbia isn't actually a state, and Vermont's mandate is...well, read on...)

As the 2020 Open Enrollment Period rapidly approaches (it starts November 1st nationwide...except for California, where open enrollment is starting on October 15th), it's time to start getting the word out about some important things to keep in mind this fall.

One of the most critical things to remember for residents of California, the District of Columbia, Massachusetts, New Jersey, Rhode Island and Vermont is that each of these states* has reinstated an individual healthcare coverage mandate law/ordinance to replace the federal ACA mandate penalty which was zeroed out by Congressional Republicans back in December 2017. This means that if you live one one of them, unless you receive an affordability, hardship or other type of acceptable exemption, you'll be charged a financial penalty when you file your state/district taxes for 2020 in spring 2021 if you don't have qualifying healthcare coverage.

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

A week or so ago I reported that Covered California had released their preliminary 2020 ACA individual market premium rate changes, with a record-low 0.8% average increase statewide. They detailed in the report how the combination of reinstating the ACA's individual mandate penalty and using that funding to provide additional financial subsidies to the enrollees lowered the average rate increases from 4.0% to 0.8%, saving unsubsidized enrollees around 3.2 points or $167/year on average.

Today, CoveredCA has posted more details about some of the specifics:

Covered California Releases Regional Data Behind Record-Low 0.8 Percent Rate Change for the Individual Market in 2020

OK, it feels a bit surreal to post about California's 2020 ACA premiums--and especially mentioning the fact that they're reinstating the ACA individual mandate penalty at the state level--on the very same day that the entire ACA itself is on the brink of complete oblivion (again), due specifically TO the fact that Congressional Republicans repealed the federal mandate penalty..

And yet, here we are:

California’s Initiatives Will Lead to Hundreds of Thousands Gaining Health Care Coverage With Lower Premiums and New Financial Help

As I've noted several times, one of the biggest flaws in the Affordable Care Act is a very simple one on paper: The Subsidy Cliff. People who enroll in ACA exchange policies are entitled to financial assistance on a sliding scale...but only if their household incomes fall between 100-400% of the Federal Povery Level. Those below the lower threshold (actually, below 138% FPL) are expected to enroll in Medicaid, but those over the upper threshold of 400% FPL (around $50,000/year for a single person, roughly $103,000/year for a family of four) are completely on their own.

Here's the current federal premium subsidy formula (the precise premium cap percentages change slightly from year to year...and the Trump Administration is even messing with that a bit, so I'm not sure what it'll be in 2020):

Yesterday I noted that both houses of the California state legislature (Assembly and Senate) voted to expand Medi-Cal (the state's Medicaid program) to anywhere between 147,000 - 175,000 undocumented immigrants (young adults age 19 - 25 and seniors over 65), entirely funded using state dollars.

It turns out that this was only part of a marathon voting session yesterday over the past few weeks. Either the state Senate, Assembly or both have also voted to pass three a bunch of other healthcare-related bills (I've included simple descriptions of each):

BREAKING: California Assembly passes our #AB1246(@Limon) to align consumer protections for all Californians, including those in large group coverage. #Care4AllCA

Back in 2016, California passed an important bill which allowed undocumented children to enroll in the state's Medicaid program (called Medi-Cal). The costs are borne entirely by the state, since federal law currently doesn't allow federal taxpayer dollars to be used to pay for Medicaid...although, I should note, this isn't entirely true:

Federal law generally bars illegal immigrants from being covered by Medicaid. But a little-known part of the state-federal health insurance program for the poor has long paid about $2 billion a year for emergency treatment for a group of patients who, according to hospitals, mostly comprise illegal immigrants.

The lion’s share goes to reimburse hospitals for delivering babies for women who show up in their emergency rooms, according to interviews with hospital officials and studies.

via Covered California:

Covered California Announces Grants to Community-Based Organizations Across California in Preparation for 2020 and Beyond

  • Community-based organizations and clinics will receive a total of $6.3 million in grant funding to help people enroll in quality health care coverage.
  • The 105 organizations reflect California’s diversity and will target populations that are hard to reach, uninsured and eligible for financial help through Covered California.
  • Approximately 89 percent of Californians live within a 15-minute drive of these community-based organizations.

Covered California announced Friday that it intends to partner with 105 community-based organizations to educate consumers about their health care options, offer in-person enrollment and renewal assistance and provide ongoing support on how to get the best value from their health plan. The Navigator grants announced are part of Covered California’s ongoing commitment to support robust marketing and outreach, including working with trusted organizations throughout the state to help hard-to-reach people understand this new era of health care.

Back in January, I noted that California Governor Gavin Newsom was proposing a stripped-down version of one of the most important ACA 2.0 provisions I've been pushing for years now: Raising the ACA's APTC subsidy income eligibility cap and beefing up the underlying subsidy formula.

At the time, he was

Well, the latest official revision to the proposed CA 2019 - 2020 state budget has been released, and not only are both the mandate reinstatement and the enhanced subsidies included, the subsidies have actually been increased a bit more than Newsom was originally proposing:

EXPANDED SUBSIDIES TO PROMOTE AFFORDABLE COVERAGE

To improve affordability and access to health care, the Governor's Budget proposed subsidies to help more low and middle class Californians afford health coverage through Covered California.

via Covered California:

New Analysis Finds Leading State-Based Marketplaces Have Performed Well, and Highlights the Impact of the Federal Mandate Penalty Removal

  • The report examines the impact that federal and state actions have had on state-based marketplaces and the federally facilitated marketplace (FFM).
  • Cumulative premium increases in California, Massachusetts and Washington are less than half of the increases seen in FFM states, but 2019 premium increases spiked in California and Washington compared to Massachusetts, which continued its state-based penalty.

WASHINGTON D.C. — A new report highlights the benefits of state-based exchanges, particularly in the areas of controlling premium costs and attracting new enrollment. The report, which was produced by Covered California, the Massachusetts Health Connector and the Washington Health Benefit Exchange, found that premiums in these states were less than half of what consumers saw in the 39 states that relied on the federally facilitated marketplace (FFM) between 2014 and 2019.

I don't analyze or write about the ACA's SHOP (Small business Health Options Program) exchange enrollment very much these days. The main reason for this is that SHOP enrollment is extremely difficult to come by. The federal exchange (HealthCare.Gov) has mostly pretended the program doesn't even exist, at least when it comes to enrollment...in fact, to my knowledge, they've only issued a single hard number for HC.gov SHOP enrollment...in 2015:

On November 15th, 2014 we launched the HealthCare.gov portal for 33 states to enroll in SHOP Marketplaces. As of May 2015, approximately 85,000[1] Americans have 2015 coverage through SHOP Marketplaces with about 10,700 small employers participating in SHOP Marketplaces. These totals do not include employers that began coverage in 2014 and have not yet renewed their coverage through HealthCare.gov for 2015.

Pages