Reinsurance

I posted Wisconsin's preliminary 2020 rate filings in early August. Yesterday the state insurance department posted this press release, which includes the final, approved rate changes. As far as I can tell, nothing has changed (the final statewide weighted average is a 3.2% average premium reduction over last year, thanks primarily to them implementing a fairly robust ACA Section 1332 reinsurance waiver:

​Gov. Evers Announces More Health Insurance Options for Wisconsinites in 2020 Ahead of Open Enrollment

With my big MLR Rebate project finally out of the way, I have a backlog of other write-ups, including several approved 2020 premium rate changes. First up is tiny Rhode Island.

As you may recall, back in July the Rhode Island insurance commissioner announced that the state was following New Jersey's model: They're reinstating the individual mandate penalty, and using the revenue from that to help fund their just-approved state reinsurance program to reduce unsubsidized premiums by 5-6 percentage points:

If approved, Rhode Island would have a $14.7 million reinsurance program for 2020 funded through the individual mandate penalty and federal pass-through funding. Rhode Island estimates a federal pass-through rate of 43 percent. Of the $14.7 million, the federal government would contribute less than half of the funds (about $6.4 million), and the state would contribute about $8.3 million.

I noted last month that Rhode Island was the latest state to put in for an ACA Section 1332 reinsurance program waiver:

Governor Raimondo’s proposed FY 2020 budget called for the creation of the Health Insurance Market Integrity Fund, which would make available reinsurance payments to health plans to reduce the burden of high cost claims on individual market premiums. According to insurer filings, the enactment of the Health Insurance Market Integrity Fund would reduce the individual market premium requests from 6.6% to -0.4% for BCBSRI and from 5.4% to 1.7% for NHPRI. These insurers’ pricing assumptions are subject to review and verification by OHIC. Table 1 shows the requested individual market rate increases with and without reinsurance.

via the Montana Insurance Commissioner's office:

REINSURANCE LOWERS HEALTH INSURANCE RATES FOR 2020

  • New Program Championed by Rosendale Leads to Double-Digit Rate Decreases in the Individual Market

HELENA, Mont. – State Auditor Matt Rosendale announced today that every health insurance plan sold on the individual market in Montana will have lower rates next year, largely due a new program that he’s championed for the past two years.

 

I wrote last month that Highmark BCBS, the sole individual market carrier operating in Delaware, has requested a 5.8% average premium reduction for 2020. In the press release from the state insurance department they noted:

It is important to note, that the proposed rate decrease is unrelated to Delaware’s intended submission of a 1332 Waiver to establish a reinsurance program. If the application process is successful, the actuarial consultant’s projections are correct, and the State of Delaware secures adequate funding, the waiver program may decrease rates by an additional 20%.

Well, today CMS indeed approved that ACA Section 1332 Reinsurance program waiver:

I feel kind of stupid posting this in the aftermath of not one, but two massacres in El Paso, TX and Dayton, OH (at least one of which was a clear case of white nationalist terrorism inspired and encouraged by Donald Trump), but I was bout 80% done with this last night and this is part of my job, so here it is.

Wisconsin Governor Tony Evers posted the following press release:

Gov. Tony Evers today announced that 2020 rates on Wisconsin’s individual health insurance market will be 3.2 percent lower on a weighted average compared to 2019 rates. This encouraging news further demonstrates that the individual market is stabilizing and Wisconsin residents are able to access more affordable coverage options.

The rate decrease also highlights the positive impact of that the Wisconsin Healthcare Stability Plan (WIHSP), or the state’s reinsurance program, is having on the individual market. WIHSP was fully funded in the recently signed 2019-2021 state biennial budget. Without the WIHSP, rates in the individual market were expected to increase by 9 percent in 2020.

As I've explained before, Section 1332 of the ACA itself gives individual states the right to petition to make changes in how the law works in their state. The idea is that, as President Obama noted himself, if a state can come up with ways to make the ACA provide coverage which is at least as comprehensive to at least as many people as it already does, without increasing the federal deficit, go for it.

There've been a couple dozen 1332 waivers which have made it at least partway through the development process; some failed along the way, some were completed but then rejected by CMS, and some have been approved. The most common type of approved 1332 waiver, in nearly a dozen states now, is for reinsurance, which is a wonky way of leveraging state dollars to reduce premiums for unsubsidized ACA enrollees.

If you're wondering why you've only heard about "reinsurance waivers" over the past year or two, there's two reasons.

I wasn't expecting my analysis of Rhode Island's 2020 ACA premium changes to be of any particular interest; it's a small state with only two carriers offering individual market policies, after all, so there's not usually much to it.

When I last checked in on the Ocean State (seriously...that's their official slogan for whatever reason), I had noted that the state Senate had passed a bill (2019-S 0738A) which, if signed into law, would lock in most of the ACA's "Blue Leg" protections, including guaranteed issue, community rating, removal of annual/lifetime coverage caps and so forth.

This just in via the Colorado Dept. of Insurance:

Polis Administration Projects 18.2% Average Decrease in Premiums for Individual Health Insurance Plans in 2020

Reducing health care costs has been a top priority for Polis.

DENVER (July 16, 2019) – Today, the Colorado Division of Insurance (DOI), part of the Department of Regulatory Agencies (DORA), announced that for the first time ever, Colorado health insurance companies that sell individual plans (for people who do not get their health insurance from an employer or government program) expect to reduce premiums by an average of 18.2 percent (-18.2%) over their 2019 premiums, provided the reinsurance program is approved by the federal government. These are the health insurance plans available on the Connect for Health Insurance Exchange, the state’s health exchange made possible by the Affordable Care Act (ACA).

This Just In from the Delaware Insurance Dept...

Dover, DE -- Highmark Blue Cross Blue Shield of Delaware (Highmark BCBS) has submitted its required annual rate filing to the Delaware Department of Insurance. After years of substantial increases, Delaware’s Marketplace has stabilized and premiums have decreased. Highmark BCBS, the only insurer continuing to offer insurance coverage in Delaware’s individual market, has proposed a 5.8% decrease for 2020. The proposed 2020 rate decrease will affect over 20,000 Delawareans.

The decrease comes after last year’s 3% rate increase and the Department’s decision to silver load. By applying the rate increase to silver level plans only, a practice known as ‘silver-loading,’ Delaware’s Marketplace received more federal subsidies, helping to assist in stabilizing the market and lowering premiums.

This Just In from the Montana Insurance Commissioner's office:

2020 Rate Filings and Rate Review

Insurance companies offering individual and small group health insurance plans are required to file proposed rates with the Montana State Auditor’s Department of Insurance for review and before plans can be sold to consumers.

What is rate review?

The rate review process, established by the Montana Legislature in 2013, does not give the Commissioner the authority to disapprove rates or prevent them from taking affect. It does give the commissioner the chance to review the factors insurance companies use in setting rates.

If the commissioner finds a rate increase to be excessive or unjustified, the insurer can voluntarily lower the rate increase. If the insurer decides to use the rate anyway, the commissioner will issue a public finding announcing that the rate is unjustified.

What does the department consider?

 

via Delaware Business Now:

Legislation calls for reinsurance program to aid people with extremely high health insurance premiums

Lawmakers have introduced legislation this week that would create a reinsurance program to help lower the cost of premiums for Delawareans who do not get insurance through their employers.

House Bill 176, which has no Republican co-sponsors, would stabilize the individual health insurance market and help Delawareans struggling with extremely highhealthcare costs to get relief, a release from House Democrats stated.

Politically, it's generally better to underpromise and overdeliver. Unfortunately, when it comes to the actual legislative process it's usually the other way around.

Case in point: Connecticut.

It was just twelve days ago that Connecticut Governor Ned Lamont rolled out his proposed ACA improvement policy package, which included a bunch of key elements including the ballyhooed "Connecticut Option"...a Public Option which would have opened up the existing state employee healthcare plan to anyone on the individual or small group markets.

The full suite was supposed to include nine major provisions:

Back in March, I noted that Democratic Minnesota Governor Tim Walz had put forth a pretty ambitious budget proposal, which included two pretty eyebrow-raising ACA-related funding proposals:

The Governor will take immediate action by creating a subsidy program to reduce by 20 percent the monthly premiums for Minnesotans who receive their insurance through MNSure. This subsidy will be applied directly against a consumer’s premiums. This proposal provides relief to Minnesotans with incomes over 400 percent of the federal poverty level do not qualify for the federal premium tax credit which helps lower the costs of health insurance premiums. Up to 80,000 people could participate in the program, reducing the out-of-pocket costs of their health insurance premiums.

A few days ago I noted that North Dakota had jumped onto the ACA reinsurance train; now it looks like Montana is onboard as well:

Governor Signs Bill Meant to Lower Some Insurance Premiums

HELENA — Gov. Steve Bullock has signed legislation meant to lower premiums for Montana customers who receive health insurance through the Affordable Care Act’s individual marketplace.

Bullock signed the bill Tuesday creating a reinsurance program to help reimburse insurers for high-cost claims so those costs aren’t included in determining individual marketplace premiums for the following year.

U.S. health officials also must approve the plan, which is estimated to offset 2020 premium increases by 10% to 20%.

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