Your Help Needed: CrowdSourcing Off-Exchange Enrollments

Since October, dozens of you have been assisting with the ACA Signups project by providing press releases, reports and news items containing data about exchange-based enrollments in both private and publicly-funded healthcare plans. Once in awhile, you've also provided stories about interesting related topics, and I'm eternally grateful for all of it. Now I'm going to ask for help in tackling the Holy Grail of ACA enrollment data.

Until recently, the "Off-Exchange" (or "Direct") Enrollment category has been something of a Great White Whale for me (yes, I know I just switched metaphors; roll with it): I knew that they were several million of them out there, but wasn't able to properly document hard data about any of them.

My first success on this front was at the end of January, when CoOportunity Health of Iowa and Nebraska helpfully provided official documentation of about 28,000 off-exchange enrollments in the two states. At around the same time, I also was led to an interview with the CEO of WellPoint Insurance (which operates as Blue Cross Blue Shield and several other names in various states), where he confirmed another roughly 95,000 off-exchange enrollments across about a dozen states.

Things stood there for several more weeks, until about 10 days ago, when I stumbled across a nice bombshell out of Washington State: The insurance commissioner revealed that there have been 184,000 off-exchange enrollments state-wide between October and the end of January. Since neither CoOportunity nor WellPoint operate in Washington State, I was able to add all of these folks. On the same day, I had another 148,000 off-exchange enrollments, nationwide, drop in my lap when I read an article about eHealth Insurance, a private web-based insurance exchange which has reported great success last fall, between October and December (they actually reported about 153,000, but I lopped off 3% to avoid double-counting Washington State).

So, that has brought the total to around 456,000, which is a nice start...but this only includes perhaps a couple dozen companies out of the couple hundred operating across the 50 states (+DC). The reason this data is so difficult to get ahold of is that, since these enrollments aren't done through one of the government-run exchanges, there's no legal requirement for the insurance companies to report them (or, in states like Washington where they're apparently required to report the figures to the Insurance Commissioner, there's no guarantee that the state Commissioner will release this data publicly).

So, in most cases, there's only two ways these enrollments will go public: Either someone from the company voluntarily released it in an interview or press release, or someone calls them up (or emails them) to ask if they'd mind giving it out. Needless to say, the latter method requires a heck of a lot of time and effort, with no guarantee of any results.

That's where you guys come in.

I've been so busy dealing with all of the other kinds of enrollments (Exchange QHPs, Medicaid/CHIP, sorting out Paid vs. Unpaid, etc.) on top of, you know, living my life (contrary to popular opinion, I actually do have a wife, kid and day job that I occasionally tend to), that I really haven't had the time to properly pursue this avenue. Plus, I'm not a professional journalist, nor do I have any real credentials other than this site, so I'm not even sure how to approach the companies. Part of me has been considering not really worrying about it; if the info comes into my hands, great, but I'm not gonna bother pursuing it.

Until today, when the following stories were brought to my attention:

A memo issued by the Obama administration on Thursday opened up alternative avenues for Oregonians to make up for lost coverage time and federal tax credits caused by the technical problems at the Cover Oregon health insurance exchange.

The updates from the Centers for Medicare & Medicaid Services come after Gov. John Kitzhaber’s office has worked with the federal government to work out a solution for Oregonians negatively impacted by Cover Oregon’s disastrous rollout....

But with technical delays forcing Cover Oregon to use the much slower manual process to process applications, many Oregonians were delayed in obtaining health insurance, if not lost in the mix.

The CMS memo not only applies to Oregonians in what it calls “exceptional circumstances,” it also allows the same flexibilities to the rest of the country.

And what is this solution, you're asking?

- If an individual diverted the exchange and enrolled in a health plan directly through a carrier, and the health plan is also offered on the marketplace, the marketplace can treat the enrollees as if they made their arrangements through the exchange.

Yes, that's correct: If this goes through as planned, potentially millions of people who enroll directly through the insurance companies (instead of via the ACA exchanges) will still qualify for tax credits.

This means that tracking down those direct, off-exchange enrollments just became even more vitally important to seeing a full picture of the total number of people covered by private insurance policies.

To that end, I'm looking for people to help out with the following:

• Contacting the office of your State Insurance Commissioner (if your state has one) to see if they have this data and whether they're willing to publicize it, or
• Contacting the public/media relations representative of any of the insurance companies operating in your state to see if they have it and are willing to publicize it

The former (insurance commission office) would be more ideal, since I'm really more interested in a state-by-state breakdown than trying to piece together a bunch of companies, but I'll take either. Also, insurance commission offices are presumably going to be more forthcoming with this data than private insurance companies, who tend to only release it if they're required to or if doing so would serve their business interests.

If you're interested in helping out with this project, fill out the submission form (which now includes new fields for Direct enrollments and PDF file uploads) with whatever you have and I'll take a look If everything checks out, I'll post the numbers and give you credit (if you want it), just like I'm already doing with the exchange-based data.

It's important, however, to make sure that:

1. We're talking about direct enrollments, not exchange-based. If they want to include both, that's fine and is still useful to have (case in point: Washington State had more than twice as many direct enrollments as it did exchange-based through the end of January), but I definitely need to know the direct number. In Insurance Commission cases, if they provide the total number, I should be able to subtract out the exchange-based ones, but I can't do that with individual insurance companies.
2. If the data comes from a private insurance company or co-op, it would be ideal if they'd provide a state-by-state breakdown, like CoOportunity did. However, a total number (like those provided by WellPoint and eHealth) will suffice if state-by-state isn't available.
3. The direct enrollments should ideally be specified as being ACA-compliant. This is important because Pres. Obama famously/infamously gave an optional 1-year "grandfather" extension on non-compliant policies, which some states took up and others didn't (see the "1YX" column on the QHP Spreadsheet to see which states are allowing these). Again, it'd be interesting to know how many of the "Junk" (or simply "Decent, just not Compliant") enrollments there are, but that's not the main point of this exercise.
4. It's also important that the data only include policies enrolled in since October 1st, and it'd be ideal if they could also provide a thru date...that is, how recently do the enrollment figures run through?
5. Possibly the most important thing: Please make it very clear to the Insurance Commission or Insurance Company representative that I need permission not only for the data to be posted publicly on the website, but the source of the data. That is, I'll need to be able to publicly link to some sort of formal report, press release or at least a PDF of their email. I'm not trying to get anyone fired or in trouble here. If they're not sure whether it's OK to release the data, ask them to check with their supervisor. If anyone needs to contact me directly to verify who I am and what this site is about, feel free to forward their contact info to me and I'll get in touch directly.

OK, I think that's about it. Hopefully this will get some results, but we'll have to see.

Thanks again for all your help,

--Charles