START OF 2018 OPEN ENROLLMENT PERIOD

Time: D H M S

Turd in the punch bowl: Up to 200K renewed enrollees to be dropped on 2/28

Amid today's otherwise excellent news out of HC.gov, WA, MA, RI & VT, there was one other unexpected bit of news from the Centers for Medicare & Medicaid Services:

The Marketplace is constantly changing with new consumers coming in each day and others leaving because of career changes, getting married or other life status changes. We have a responsibility to make sure people who are eligible stay covered and that those who are not eligible for Marketplace coverage do not. Up to 200,000 Marketplace consumers who had 2014 coverage cannot continue Marketplace coverage in 2015 because they did not provide the necessary documentation of their citizenship or immigration status. They will be notified in the coming days that their coverage ends on February 28. This is the same process that started last year and will continue on a regular basis.

Last fall, as you'll recall, 112K people were dropped from their ACA exchange coverage last fall for these immigration/citizenship/legal residency issues. I've confirmed the distinction between those 112K and these 200K: The earlier batch never responded to repeated attempts at communication; they were basically "radio silent", and were thus dropped at the time. These 200,000 people responded to the verification request, but apparently after several more months of trying, simply were never able to prove their legal right to keep their coverage, so they're being given the boot at the end of February.

I've alrady been asked how I think this will impact the enrollment numbers. The answer is, it won't impact my top of the line projection (12.5 million QHP selections) whatsoever. It also shouldn't impact my paid QHP projection (11.0 million paying their first month's premium), since the issue at hand is not failure to pay, but lack of proof that they should be enrolled in exchange policies in the first place.

What it will likely impact is my end of year attrition projection, which until now I was assuming would be around 10.5 million people still paying/effectuated by December 2015.

Last year, the numbers played out like so: 8.0 million plans selected >> 7.1 million paid >> 6.7 million still enrolled by late October

However, 112K of that 400K gap (7.1M > 6.7M) was made up of the first batch of "legal residence issues" people. 

I have no idea whether this year will follow a similar pattern, but assuming a worst-case scenario, it sounds like we could be looking at perhaps 10.3 million still enrolled by the end of the year. On the other hand, if the remaining enrollments stay stable, it could still end up at 10.5 million or even higher.

Plus, of course, it's possible that the top number will be even higher than 12.5 million to begin with. Maybe it'll be 12.7 million and this will just cancel that out.

So no, I'm not freaking out about this development, but it's certainly not positive news.