I've written quite a few entries bashing the Short-Term Plan portion of Donald Trump's executive order opening up the floodgates on non-ACA compliant policies. However, I've written far less about the other shoe he's dropping: Association Health Plans, or AHPs. In fact, while I discussed AHPs briefly in Part Two of my Risk Pool video, the only blog post I've written to date which specifically focuses on them just quoted from this Avalere Health article:
Association Health Plans (AHPs) are health insurance arrangements sponsored by an industry, trade, or professional association that provide health coverage to their members—typically small businesses and their employees. Health insurance coverage offered through AHPs aims to make coverage available and affordable for small groups and individual employees. Importantly, these arrangements are currently governed by state and federal requirements and are subject to state oversight, including standards related to premiums and benefit requirements.
Polls in 6 Battleground States Show Voters Blame Republicans for Rate Hikes
Six new Public Policy Polling surveys in battleground states find voters will blame Republicans for the expected health care premium increases this summer by approximately 30 points and voters believe Republicans and President Trump have been actively undermining and sabotaging the Affordable Care Act.
ARIZONA Voters say they will blame Republicans if health care premiums increase this summer. 55% say they will hold Republicans in Washington responsible if rates increase, compared to just 29% who said they would not. A plurality of voters (49%) say they believe Washington Republicans and President Trump have been trying to undermine and sabotage the Affordable Care Act – and a majority of independent voters (57%) also say they agree with that statement.
OK, this doesn't technically count as an official 2019 Rate Hike analysis since none of it comes from actual carrier rate filings, but Covered California, the largest state-based ACA exchange, just released their proposed 2018-2019 annual budget, and it includes detailed projections regarding expected premium increases and enrollment impact over the next few years due specifically to the GOP's repeal of the ACA's Individual Mandate. Oddly, while they mention short-term plan expansion as another potential threat to enrollment/premiums, they do so passingly, and they don't mention association plans at all:
Since 2014, nearly 5 million people have enrolled in Medi-Cal due to the Affordable Care Act expansion, and more than 3.5 million have been insured for some period of time through Covered California. Together, the gains cut the rate of the uninsured in California from 17 percent in 2013 to a historic low of 6.8 percent as of June 2017.
Last month, after much painstaking research and analysis, I concluded that unsubsidized ACA-compliant individual market enrollees (both on & off the exchanges) are paying an average of around $960 this year (~$80/month) more in healthcare premiums nationally in 2018 than they otherwise would be if not for the various forms of ACA sabotage carried out by Donald Trump and Congressional Republicans last year.
Again, it's important to clarify that this is $960 more (around 17% more) in addition to non-sabotage-related factors such as normal medical expense inflation (around 7%), the reinstatement of the ACA carrier tax (about 2%) and other various/sundry factors (around 2%).
Back in mid-April, I crunched a bunch of numbers and concluded that around 6.5 million people enrolled in unsubsidized ACA-compliant individual market policies are, on average, paying an additional $960/year ($80/month) for their policies this year due specifically to last year's sabotage efforts by Donald Trump and Congressional Republicans. This is separate from other factors such as medical trend and the reinstatement of the ACA carrier tax. The actual 2018 "Trump Tax" ranges from as little as almost nothing at all in Vermont and North Dakota to as high as $1,500 per enrollee in Mississippi and Pennsylvania.
The 2018 sabotage impact was mainly due to 1) CSR reimbursement funding being cut off; 2) uncertainty over individual mandate enforcement; and 3) a mish-mash of Open Enrollment changes including cutting the time window in half, slashing marketing/assistance budgets by 90% and 40% respectively and so forth.
The Kaiser Family Foundation just released an important new study which proves everything I've been saying for the past year and a half: After years of turmoil, the ACA-compliant individual market had finally quieted down and reached equilibrium last year...right up until Donald Trump, combined with total GOP control of the federal government, deliberately came in like a wrecking ball and messed everything up again:
Concerns about the stability of the individual insurance market under the Affordable Care Act (ACA) have been raised in the past year following exits of several insurers from the exchange markets for 2017, and again last year during the debate over repeal of the health law.
Oregon just became the 4th state to submit their preliminary 2019 ACA individual market rate filings, and while the expected increase is smaller than expected on average (in part due to Oregon's strict control of short-term plans), repeal of the individual mandate by Congressional Republicans and Donald Trump are still responsible for the vast majority of the rate increase.
Normally, I don't start posting natoinal projections for my annual Rate Hike Project until I have at least filing data for at least a dozen or so states because the national weighted average jumps around so much early on. A "national average" of, say, 10% based on numbers from, say, Vermont, Wyoming and the District of Columbia (collective population: 1.9 million people) is gonna change radically once you add California or Florida to the mix if they're looking at a 20% hike, for example.
Having said that, seeing how advocacy organization Protect Our Care has decided to launch their own version of my Rate Hike Project, and seeing how I do have preliminary 2019 rate increase projections from at one large state (Virginia) and two mid-sized states (Maryland and Oregon), I've decided to go ahead and start posting the national projections early, with a major caveat that the national average will likely change dramatically until at least 2/3 of the states have been plugged in.
Given how progressive Vermont is, you'd think that they'd be doing as much as possible to batten down the hatches in order to avoid or mitigate the latest wave of sabotage efforts from the Trump Administration and the GOP...and you'd mostly be correct.
Some of the work on that front has already been done. For one thing, Vermont (along with Massachusetts and the District of Columbia) merges their individual and small group market risk pools together, which helps smooth out premium increases and overall morbidity across a larger risk pool. For another, Vermont has fully embraced ACA provisions such as Medicaid expansion and operating their own full exchange, of course. Vermont, along with a few other states, also has pretty strict rules in place limiting both short-term and association healthcare plans, so that portion of Trump's sabotage attack is neatly cancelled out already.
Louise Norris is an awesome source for all sorts of healthcare policy/insurance data, but she's especially on top of developments in her home state of Colorado, where she and her husband Jay run a small brokerage outlet.
Today Jay and Louise have a couple of interesting tidbits out of The Centennial State (yeah, I had to look up their nickname myself).
That's (sort of) an 88% retention rate through early May. I say "sort of" because this presumably includes some amount of churn (if 100 people drop coverage and 100 off-season enrollees sign up, that'd be a net change of zero). Even so, it's actually slightly better compared to prior years, when the national effectuation number had usually dropped to around 87% by the end of March.
Insurers selling Obamacare plans in Maryland are again seeking huge rate increases for 2019, but they could be knocked down significantly by a reinsurance program the state hopes to implement for next year.
CareFirst BlueCross BlueShield wants to increase rates on average by 18.5 percent on its HMO plans, which account for more than half of the individual market this year.Kaiser Permanente, the only other insurer selling on the exchange, is seeking a 37.4 percent average increase on its HMO plans, which cover just over a third of Obamacare customers.
A couple of days ago, I posted that Virginia has become the first state out of the gate with their preliminary 2019 premium rate requests for ACA individual policies. However, I made sure to emphasize that these are preliminary requests only; carriers often resubmit their rate change requests more than once over the course of the summer/fall, and even that may not match whatever the final, approved rate changes are by the state insurance commissioner.
In addition, I generally try to make it understood that there's alotof room for error here--the weighted averages are based on the number of current enrollees, but of course that number can change from month to month as people drop policies or sign up during the off-season (via Special Enrollment Periods). Even then, the rate filing paperwork is often vague or confusing about just how many enrollees they actually have in these plans. Sometimes wonks are reduced to taking the number of "member months" and dividing by 12 to get a rough idea of how many people are enrolled in any given month. Sometimes the only number of enrollees available are from last year, which could bear zero resemblence to how many are currently enrolled. Sometimes the only number available is how many people the carrier expects to enroll in their policies next year. And so on.
Aside from Virginia, it's likely going to be another month or so before the 2019 ACA policy rate filings start trickling in, since the deadline for initial rate requests isn't until late June in most states. However, there's some interesting non-ACA policy filing stuff which is available as well. Given all the concern about non-ACA compliant policies siphoning healthy people away from the ACA market, I figured I should take a look at a few of these.
Here in Michigan, I've found three such filings: One is for "transitional" plans from Golden Rule (a subsidiary of Unitedhealthcare, I believe). The other two are for "short-term" plans (the type which Donald Trump is basically removing any regulation on).
IMORTANT UPDATE: As I suspected, it turns out that the stray rate filing posted to the California Insurance Dept. website a few days ago was posted prematurely, doesn't reflect the carrier's final* rate filing, and has since been pulled from the California Insurance Dept. website.
I've been asked to remove the filing data, and seeing how there's nothing nefarious about it (I wasn't "whistleblowing" evidence of anything criminal/unethical), I'm complying with that request. Since everything in the post related to that data, there wasn't much point in keeping the rest of it either.
*(Yes, I'm aware that none of these early filings are "final" since they tend to be revised/resubmitted throughout the summer/fall, but you know what I mean.)