Mandate Repeal

2019 OPEN ENROLLMENT ENDS (most states)

Time: D H M S

*"Not as bad as expected" depends on your perspective. Even the 6-7-point average premium increase caused by mandate repeal is still an average of $430 - $500 per unsubsidized enrollee for the year...or $1,300 - $1,500/year for a family of three.

Earlier this year, most healthcare wonks (along with the Congressional Budget Office) projected that Congressional Republicans repealing the ACA's individual mandate last December (effective January 1, 2019) would have a significant Adverse Selection impact on the ACA-compliant individual market risk pool. Projections of the premium increases imposed in response to the drop-off of healthy enrollees ranged from 10% (CBO) to as high as 16.6% (Urban Institute, although that also included a small increase due to Trump's expansion of short-term plans as well).

As I noted a few days ago, now that the 2019 ACA Open Enrollment Period is actually underway and the approved individual market premium rate changes have been posted publicly for every state, I'm finally able to go back and wrap up my 2019 Rate Hike Project for the nine states which I was still missing final numbers for.

As I further noted, the approved rates in most of those states didn't change much compared to the preliminary/requested rate changes I had already analyzed earlier this year:

I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.

Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these.

Nebraska has a slightly confusing siutation, which is surprising since Medica is the only carrier offering ACA policies in the state, When I first took a look at the requested premium changes for 2019 back in August, it looked like the average was around 1.0%...that was based on splitting the difference between the 3.69% and -2.60% listings, since the filing form was redacted and I didn't know what the relative market split was between Medica's product lines.

I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.

Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these.

West Virginia's requested average rate increase was among the highest in the country for 2019--a weighted average of around 14.9%.

However, while state insurance regulators left one of the three carriers offering individual market policies alone, they knocked the other two down substantially: CareSource was lowered from around 13.1% to 9.5%, while Highmark Blue Cross Blue Shield was lowered from an average of 15.9% to 9.0%.

I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.

Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these. In addition, in a few states the insurance department has also posted their own final/approved rate summary.

I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.

Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these. Making things even easier (although not necessarily better from an enrollee perspective), in three states the approved rates are exactly what the requested rates were for every carrier: Alabama, Mississippi and Utah:

This is about as minor a rate filing update as I've had, but I'm posting it separately in the interest of completeness.

Insurance carriers in my home state of Michigan originally submitted their requested 2019 ACA individual market rate filings back in June. At the time, the average premium increase being asked for was pretty nominal, around 1.7%, with a smaller-than-average #ACASabotage factor of around 5% due to the ACA's Individual Mandate being repealed and #ShortAssPlans being expanded by the Trump Administration.

Today, just two days before the 2019 Open Enrollment Period actually begins, the Michigan Dept. of Financial Services finally posted the approved 2019 rate filings...and practically nothing ended up changing.

There was practically no change whatsoever between the rate changes requested by Louisiana carriers for the 2019 ACA individual market and the rates approved by the state insurance regulators. However, it's still good to be able to lock in the official rates just ahead of the Open Enrollment Period itself, including the individual filing data.

Overall, unsubsidized premiums should drop around 6.5%, which is good news...except that, once again, if it weren't for the ACA's individual mandate being repealed and #ShortAssPlans being expanded by the Trump Administration, I estimate they'd be dropping by another 9.3%, give or take, for a total premium reduction of more like 15.8% on average.

At $649/month full-price on average this year, that means the average unsubsidized enrollee will be paying somewhere around $724 more apiece next year due to those factors.

OK, this is a pretty minor update, but in the interest of completeness I should post it.

In mid-September, the Washington State insurance commissioner posted the approved 2019 average ACA individual market premium changes for carriers statewide, coming in at 13.8% overall.

The only problem is that the report only included the seven on-exchange ACA market carriers. The four carriers which offer off-exchange policies (which are pretty much identical and are part of the same risk pool, but don't qualify for tax credits) weren't included. They make up roughly 23% of Washington State's total individual market.

Today, just a few days before Open Enrollment begins, the WA Insurance Commissioner posted the complete approved rate change information. The overall average has dropped slightly, to 13.6%:

Eleven insurers approved to sell 74 plans in Washington's 2019 individual market
13.57 percent average rate increase approved

October 29, 2018

As regular readers know, every spring/summer I spend countless hours poring over the annual insurance carrier rate filings, plugging in increases (and occasionally decreases) in ACA-compliant premium changes for every carrier in every state. I actually do this twice for most states (and occasionally even three times), as the process moves from preliminary/requested rate changes to "semifinal" rates to "final/approved" rates throughout the fall.

For 2018 and again for 2019, I've taken this one step further; instead of simply running the overall weighted average premium changes in each state, I've also attempted to break out what portion of the change is caused by various factors...in particular, what portion is caused by legislative or regulatory changes by Congressional Republicans and/or the Trump Administration.

OK, I had kind of forgotten about this. Back in early June, insurance carriers in Pennsylvania submitted their preliminary 2019 ACA market premium change requests. At the time, they averaged around a 4.9% increase statewide, which seemed pretty impressive under the circumstances.

Then, late July, the PA insurance department issued a press release stating that state regulators had modified the 2019 requests, and that the new, revised average was much lower...a mere 0.7% average rate hike. However, the individual carriers as well as the insurance department made it very clear that this nominal increase included a 6 point rate increase to account for the ACA's individual mandate being repealed and the Trump Administration's expansion of non-ACA compliant short-term and association plans.

I originally wrote about District of Columbia carrier requested 2019 ACA rate changes back in June. At the time, they were seeking a weighted average increase of around 15.5% across the District.

However, the DC exchange board was also working quickly in an attempt to counter the Trump Administration's #ACASabotage factors, by voting to restrict short-term plans, to lock in DC's Open Enrollment Period at a full 3 months as in years past, and to reinstate the ACA's individual mandate penalty at the local level.

As of early September, all of these things appeared to have been approved by the exchange board and/or the DC Council.

On September 19, the DC Dept. of Insurance, Securities & Banking posted the approved 2019 ACA rate changes, and the average increase for the individual market had been shaved down from 15.5% to 13.0%:

I analysed Kansas' 2019 ACA indy market rate changes back in August. The three carriers were requesting an average increase of around 6.1% (this may be slightly off since I had to estimate the market share for two of the three). State insurance regulators left Blue Cross Blue Shield and Ambetter's rate requests as is, but cut Medica's down by more than half, from a 10.7% increase to just 4.3%:

Premium Rates for Individual and Small Group Markets Individual plan premium rates may vary by age, rating area, family composition and tobacco usage. For example, a person living in Manhattan, KS (rating area 3) may pay a different rate than someone living in Pittsburg, KS (rating area 7) based on the claims data by rating area. A map of the counties included in each rating area is provided on the next page. Kansas is an effective rate review state, which means the actuarial review is conducted by the Kansas Insurance Department. KHIIS (Kansas Health Insurance Information System) claims data is utilized during the rate review process to verify the claims experience submitted by the companies. The following table provides details regarding the average requested rate revisions for companies writing individual policies in Kansas. Rate increases will be partially offset for individuals receiving a premium tax credit.

Back in June, Indiana's 3 individual market carriers submitted their requested 2019 ACA rate changes, which averaged around 5.1%. At the time I also pegged the impact of #ACASabotage on 2019 rates (mandate repeal + #ShortAssPlans) at around 13 percentage points.

This week I've found Indiana's approved 2019 rate changes for the individual and small group markets. State regulators cut the overall average increase for the individual market in half, to just 2.6%:

Last month, the Idaho Insurance Department posted the preliminary 2019 ACA individual market rate change requests. They were pretty straightforward, averaging around an 8% increase across the market.

A few days ago, the Idaho DOI issued their final/approved rate changes, knocking a few points off the hikes and bringing the weighted average increase down to 5%:

The Department of Insurance received preliminary 2019 health plan information from insurance carriers on June 1 and began reviewing the proposed plan documents and rates for compliance with Idaho and federal regulations. The Department of Insurance does not have the authority to set or establish insurance rates, but it does have the authority to deem rate increases submitted by insurance companies as reasonable or unreasonable. After the review and negotiation process, the carriers submit their final rate 2019 increase information. The public is invited to provide comments on the rate changes. Please send any comments to Idaho Department of Insurance.

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