California

This press release came out last week but I covered all the other state-based exchange Open Enrollment press releases so I figured I should include this one as well:

Covered California for Small Business Announces Expanded Choices and an Average Rate Change of 4.1 Percent for 2020

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):

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