On November 10, 2016, at 4:30 in the morning, I was still in a bit of a dazed state trying to absorb the reality that a racist, misogynistic, xenophobic con-artist sexual predator moron was about to become the next President of the United States. We were 9 days into the 2017 Open Enrollment Period, and I realized that there was absolutely no way of knowing what sort of impact the election results might end up having on how many people would sign up for coverage.
Up until a week ago, the possibility of Donald Trump pulling the plug on Cost Sharing Reduction reimbursement payments was a looming threat every day. While it hadn't actually happened yet, most of the state insurance commissioners and/or insurance carriers themselves saw the potential writing on the wall and priced their 2018 premiums accordingly (or at the very least prepared two different sets of rate filings to cover either contingency).
A few spread the extra CSR load across all policies, both on and off the exchange. This seems like the "fairest" way of handling things on the surface, but is actually the worst way to do so, because it hurts all unsubsidized enrollees no matter what they choose for 2018 and can even make things slightly worse for some subsidized enrollees in Gold or Platinum plans.
TRENTON -- New Jersey residents who bought their own health coverage from Horizon Blue Cross Blue Shield through the Affordable Care Act could pay an average of 24 percent more next year, according to state-approved rates released on Tuesday.
Horizon is one of three insurance companies in New Jersey participating in the Obamacare marketplace in 2018. But it is the most dominant, insuring 72 percent of the 244,000 individual policy holders this year.
However, I realized a little later on that I was misinterpreting KFF's analysis; they were referring to how much they estimated silver plans would go up due to the lost CSR funds, not all metal levels. Furthermore, for Medicaid expansion states (which includes Rhode Island) they estimated the average was only 15%.. Based on these factors, the impact across the board on Rhode Island should have only been around 10.3%.
Way back in May, Blue Cross Blue Shield of North Carolina submitted their initial 2018 rate requests to the state insurance department, and noted at the time that they'd normally only be requesting an 8.8% average rate increase...but that due specifically to Donald Trump's threat to cut off CSR reimbursement payments, they were asking for a 23.3% increase instead. I noted that this meant that about 60% of their increase request was caused by Trump's CSR threat.
Blue Cross said May 25 that the 22.9 percent rate increase was based on the subsidies ending, along with claims data from the first quarter of 2017. It projected an 8.8 percent rate increase with the subsidies remaining in place.
Things were looking pretty dicey for two of Montana's three insurance carriers participating on the individual market the past few days. One of the three, Blue Cross Blue Shield, saw the writing on the wall regarding Cost Sharing Reductions (CSR) likely being cut off and filed a hefty 23% rate hike request with the state insurance department. The other two, however (PacificSource and the Montana Health Co-Op, one of a handful of ACA-created cooperatives stll around, assumed that the CSR payments would still be around next year and only filed single-digit rate increases.
I'm not going to speculate as to the reasons why they both did so when it was patently obvious that having the CSRs cut off was a distinct possibility, although I seem to recall the CEO of the Montana Co-Op said something about their hands being tied since CSR reimbursement payments are legally required, after all. Basically, it sounds like he was genuinely trying to avoid passing on any more additional costs to their enrollees than they had to.
Pennsylvania is the first state which has released their approved 2018 rate hikes since Donald Trump officially pulled the plug on CSR reimbursement payments last Friday. It's also one of just 16 states which had yet to do by then. Most of the remaining states are small or mid-sized, so plugging Pennsylvania into the 2018 Rate Hike Project leaves just Texas, North Carolina and New Jersey as missing states with more than 8 million residents.
Insurance Commissioner Announces Single-Digit Aggregate 2018 Individual and Small Group Market Rate Requests, Confirming Move Toward Stability Unless Congress or the Trump Administration Act to Disrupt Individual Market
As in most states, the Michigan Dept. of Financial Services, seeing the potential writing on the wall, sent out a memo to all individual market insurance carriers instructing them to submit two different sets of rate filings for 2018: One assuming CSR payments would continue, the other assuming they won't:
Note: This post is a joint effort with colleagues who have closely tracked the CSR chaos induced by Trump and Republicans in Congress. Dave Anderson is a former health insurance analyst, now a healthcare scholar at Duke, and a blogger at Balloon Juice; Louise Norris is co-owner with her husband Jay of a unique health insurance brokerage for individual market customers, and a top source of marketplace information and analysis at her own blog as well as at healthinsurance.org and elsewhere. Andrew Sprung writes about healthcare policy on his blog, xpostfactoid, as well as at healthinsurance.org and other publications.
In August I reported that the three individual market carriers in West Virginia (CareFirst, Highmark BCBS and Health Plan of the Upper Ohio Valley) were requesting average rate hikes of around 17.8% assuming CSR payments are made or 27.8% assuming they aren't.
Medica has 35,269 members on their ACA-compliant individual market plans in 2017. But all of the current Aetna enrollees, as well as off-exchange BCBSNE enrollees, will need to switch to Medica plans at the end of 2017, as Medica will be the only insurer offering plans in Nebraska’s individual market for 2018.
A week or so ago, there was some confusing news about how Donald Trump may or may not be planning on signing a new healthcare-related executive order. I didn't write about it earlier because at first it sounded like he was talking about a meaningless "sell across state lines" decree...meaningless because the ACA already allows carriers to sell ACA-compliant policies across state lines, as long as the states in question sign onto an interstate compact.
Ambetter ("Sunflower State") is new to the state, so there's no "rate hikes" to speak of. My confusion was regarding BCBSKS, which is already on the KS exchange but didn't appear to submit any actual "rate change" request last time I checked. Louise Norris has cleared up this mystery:
The Cost Sharing Reduction (CSR) payment controversy has been sucking up a huge amount of oxygen over the past 9 months. Most of this is due to Donald Trump repeatedly threatening to cut off the monthly reimbursements to insurance carriers since January, but some of the concern was already there before he even took office. Why? Because the whole reason the CSR payments are at risk of being discontinued in the first place is a federal lawsuit filed by John Boehner on behalf of the House Republican Caucus back in 2014.
The case slowly ground it's way through the judicial process mostly under the radar for a couple of years. Law experts like Nicholas Bagley of the University of Michigan took the view that the case actually had some merit to it on the surface, but should still be shot down due to a lack of standing: