OE6

2018 MIDTERM ELECTION

Time: D H M S

A few days ago I noted that Blue Cross Blue Shield of Tennessee, which holds over 50% of TN's ACA-compliant individual market, specifically noted in their individual market rate filings that while they're lowering rates by 10.9% on average in 2019, they had been planning on lowering rates considerably more prior to the bombshell announcement that CMS has decided to "freeze" Risk Adjustment fund transfers for an unknown period of time. Specifically:

“Our rate reduction would have been larger, but we had to account for added uncertainty in our rates due to indefinite suspension (the U.S. Centers for Medicare and Medicaid Services) placed on risk adjustment transfers between insurers,” said , said Mary Danielson, a BCBST spokeswoman. “Again, we were planning a larger reduction – around 18 percent – but needed to factor in the prospect of greater costs for 2019.”

Breaking out of Nevada...

The cost of plans through Nevada’s health insurance exchange are anticipated to only increase by an average of 1.9 percent next year in what the state’s insurance commissioner said is the lowest proposed rate increase from insurance companies since the Affordable Care Act went into effect in 2014.

The announcement, made by the Division of Insurance late Tuesday morning, comes amid ongoing uncertainty about the impact that Congress’s repeal of the Affordable Care Act’s individual mandate and federal rule changes for two types of non-ACA-compliant health plans will have on the individual market as a whole. Insurance Commissioner Barbara Richardson cautioned that the proposed rates are subject to change based on any action by the federal government and said the division is working “diligently” to review the proposed rates from insurance companies.

That 1.9% figure is slightly misleading, though, because...

This year, thanks to their reinsurance program, ACA individual market premiums dropped by around 23.6% on average, from a whopping $1,040/month to "only" $795/month per enrollee.

HOWEVER, they would have dropped about 4.5 percentage points more if not for Trump cutting off Cost Sharing Reduction reimbursement payments, or roughly $560/year per enrollee. AK averaged around 16,000 effectuated ACA-compliant individual market enrollees per month in 2017, so that amounts to right around $8.9 million total. 6,930 enrollees qualify for CSR assistance this year, so that averages around $1,280 apiece in CSR help, which sounds about right to me.

Last fall I wrote a lot about how different states would be dealing with the tens of millions of dollars in losses they were facing after the Trump Administration decided to cut off Cost Sharing Reduction (CSR) reimbursement payments to them. As a quick reminder, there basically four (or five, depending on your POV) options available to each carrier and/or state insurance commissioner for dealign with CSR costs for 2018:

  • No Load: They could gamble that the CSR problem would be resolved and the payments would be made after all (i.e., they would price normally).
  • Broad Load: They could spread the CSR cost out evenly across all of their 2018 ACA policies, on exchange & off.
  • Silver Load: They could load the CSR costs onto all Silver plans only (both on & off exchange).
  • Silver Switcharoo: They could load CSR costs onto all on-exchange Silver plans only, while also creating "mirror" Silver plans off-exchange without any CSR load.
  • Mixed Load: Each insurance carrier could choose whichever of the other 4 strategies they wanted to and let the chips fall where they may. Not sure if this really counts as a "strategy", since it's more or less "all of the above".

Via the Colorado Division of Insurance:

DENVER (July 13, 2018) – The Colorado Division of Insurance, part of the Department of Regulatory Agencies (DORA), today released preliminary information for proposed health plans and premiums for 2019 for individuals and small groups. Colorado consumers can file formal comments on these plans through August 3.

2018 Companies Return for 2019
The same seven companies that offered on-exchange, individual plans are returning for 2019 - Anthem (as HMO Colorado), Bright Health, Cigna Health and Life, Denver Health Medical Plans, Friday Health Plans, Kaiser Foundation Health Plan of Colorado and Rocky Mountain HMO. And like in past years, this means that all counties in Colorado will have at least one on-exchange company selling individual health plans.

Holy guacamole. I've noted repeatedly that unlike last fall, when average rate increases of 20-30% or more were commonplace for ACA individual market policies (due mainly to Trump cutting off CSR reimbursement payments), the preliminary rate requests for 2019 are actually averageing quite a bit lower than originally expected; of the 20 or so states I've crunched the numbers for so far, the weighted average for unsubsidized premium hikes is hovering around the 10% mark.

At first glance, it may sound like Democrats have been overplaying their hand when it comes to the "individual mandate repeal/short-term plan expansion is causing massive hikes!" attack. However, the rate increases from deliberate sabotage are happening...they're just being partly cancelled out by other factors, including:

If you've followed this site for awhile, you may recall that about a year ago, I called out the Centers for Medicare & Medicaid (CMS) for trying to pull a fast one regarding the 2017 Open Enrollment Period data.

The short version is that they tried to make it look as though only 10.3 million of the 12.2 million people who selected Qualified Health Plans (QHPs) from the ACA exchanges actually paid their first month's premium and were actually enrolled (i.e., "effectuated"), or around 84%. They then tried using this "fact" as evidence of how the ACA was failing, etc etc, because this was supposedly down from 2016 levels.

The difference, as I noted at the time, is that the 2016 effectuation numbers were as of March, while the 2017 effectuation numbers were as of February. This made a big difference, because around 500,000 people who enrolled during 2017 Open Enrollment couldn't have been effectuated for February...because about half a million people enrolled between Jan. 16th - Jan. 31st, which meant their policies weren't even scheduled to begin until March.

Last week I noted that after slashing the marketing budget for HealthCare.Gov, by a whopping 90% (from $100 million to just $10 million) and cutting the Open Enrollment Period itself in half (from 3 months to just 6 weeks) and cutting the navigator/outreach budget by 41% (from $59 million down to $36 million), Trump's CMS Dept. was "considering" slashing the navigator budget for 2019 down further yet:

The Trump administration is considering cutting funding for ObamaCare outreach groups that help people enroll in coverage, sources say.

An initial proposal by the administration would have cut the funding for the groups, known as "navigators," from $36 million last year to $10 million this year. Sources say that proposal now could be walked back, and it is possible funding could remain the same as last year, but it is unclear where the final number will end up.

OK, this is very helpful! via the Robert Wood Johnson Foundation:

A year ago, rate filings caused widespread anxiety, as multiple carriers announced withdrawals from the ACA market, and state officials struggled to fill bare counties. Many of those remaining filed enormous rate increases. In 2018, marketplace enrollment was stable, while unsubsidized enrollment continued its multi-year decline. So far, this year’s rate filing season has been sprinkled with news of entry and expansion, and proposed rate hikes that are generally more moderate. With no announced market exits thus far, it seems likely that in 2019 there will be net entry into the ACA marketplace.

...Our public web tool tracks participation for 2019 at the county level. It can be used to monitor changes in the number of carriers by counties, and also provides information at the carrier level. Data can also be downloaded.

Whew! Georgia only has 4 carriers participating in the individual market, but tracking down some of the data was a royal pain in the butt, especially Ambetter/Centene, which not only buried the numbers I needed inside a whopping 1,900-page PDF file, but the actual average requested rate increase wasn't even included; for that I had to check a different file. Yeesh.

The good news is that carriers in Georgia are only requesting around a 6.1% average rate increase for ACA-compliant individual market policies next year.

The bad news is that if it weren't for the ACA's individual mandate being repealed and the Trump Administration's expansion of #ShortAssPlans, 2019 premiums would likely be dropping by around 5.8% instead.

Last summer, as part of his blatant and openly-declared attempt to undermine and sabotage the Affordable Care Act, Donald Trump's HHS Dept. slashed the marketing budget for HealthCare.Gov, the federal ACA exchange, by a whopping 90% (from $100 million to just $10 million), while also cutting the navigator/outreach budget by 41% (from $59 million down to $36 million). On top of this, they also proceeded to confuse the hell out of the grantees of those remaining funds by not providing any information or details before sending out the funds...and then changing their minds at the last minute in many cases and pulling the checks literally moments before they were supposed to be put in the mail. They also slashed the Open Enrollment Period itself in half while they were at it, from 3 months down to just 6 weeks.

For nearly a year, healthcare wonks like myself, David Anderson, Andrew Sprung and Louise Norris have been heavily getting the word out to promote not just the "Silver Loading" CSR-load workaround, but an even more clever variant which I've coined "the Silver Switcharoo" which takes the concept of Silver Loading and goes one step further.

It gets a bit complicated, but here's my explainer of how the Silver Switcharoo works for ACA individual market policies.

The bottom line is that in theory/on paper, just about everyone either comes out ahead or at least is no worse off if they use silver switching:

*(OK, these are technically only "semi-approved" rates...there could still be some additional tweaks later on after public comment, etc.)

Oregon was the fourth state which I ran a preliminary 2019 rate increase analysis on back in May. At the time, I concluded that insurance carriers were requesting a weighted average increase of 10.5% for ACA-compliant individual market policies next year. I knew that Oregon's state-based Reinsurance program was helping keep that average down to some degree, but I didn't know exactly how much of a factor it was.

I also knew that efforts to sabotage the ACA by Donald Trump and Congressional Republicans would play a major role in increasing 2019 rates: Repeal of the individual mandate is a big factor, along with the unnecessary 1-point increase in the state exchange fee being imposed on Oregon and the other four states which run their own exchange but "piggyback" on HealthCare.Gov's technology platform.

This article from KTVQ is excellent for my purposes. It clearly and cleanly plugs in just about all of the hard numbers I need to run my rate hike analysis: Which carriers are participating in the 2019 ACA individual market; how many current enrollees each carrier has (both on and off the exchange); and the exact average increase each one is requesting for next year!

Health insurers selling individual policies on the “Obamacare” marketplace in Montana are proposing only modest increases for 2019, on average – or, no increase at all.

State Insurance Commissioner Matt Rosendale released the proposed rates Thursday, with Blue Cross and Blue Shield of Montana proposing an average increase of zero – and a 4.9 percent decline for small-group policies.

The other two companies selling policies on the online marketplace, PacificSource and the Montana Health Co-op, proposed average increases of 6.2 percent and 10.6 percent for individual policies, respectively, and lesser increases for small-group policies.

 

Note: This is a follow-up to a post I wrote back in early May which was itself based on an earlier analysis by the folks at the Kaiser Family Foundation.

For weeks now, I've been painstakingly analyzing and plugging in the preliminary 2019 rate change data for ACA-compliant individual market as each state submits their filings. As of today, I've compiled data for 18 states (+DC), comprising perhaps 40% of the total ACA individual market, give or take. The table below shows where things stand at the moment.

Those yellow and manilla cells at the bottom are not a typo: To the best of my estimates so far, the insurance carriers across these 19 markets are asking for average 2019 unsubsidized premium rate increases of around 10-11%...however, as far as I can tell, they would be keeping rates FLAT year over year (on average), for the first time since the ACA launched, if not for three sabotage efforts by Donald Trump and Congressional Republicans: Repeal of the ACA's individual mandate, and Trump's removal of restrictions on non-ACA compliant "Short-Term, Limited Duration" and "Association" plans, which I've shorthanded as simply #ShortAssPlans....and in fact would actually be dropping in quite a few states (or, in the case of Minnesota, dropping more than they already are set to with those factors):

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