END OF 2018 OPEN ENROLLMENT PERIOD (42 states)

Time: D H M S

UPDATED: #ACATaxTime: 68K via HC.gov (86K confirmed nationally)

As you'll recall, in every state but 3 (CO, MA & ID), the ACA exchanges are allowing people who a) had to pay the "shared responsibility penalty" last year; b) missed the 2/22 deadline for enrolling in healthcare coverage this year and c) "didn't know" about the penalty until after the deadline (honor system!) were given a roughly 6-week period to go ahead and enroll for the rest of 2015.

A couple of weeks back I reported that I had seriously overestimated the number of people who were likely to take advantage of the ongoing tax filing season Special Enrollment Period, which I've shortened to #ACATaxTIme. The time window for most states is from 3/15/15 - 4/30/15, although a few states started a bit earlier/later.

I had made a very rough "spitball" guess that perhaps somewhere between 600K - 1.2 million people might select exchange policies during this SEP, based on extremely vague information about just how many people actually qualified.

As it turns out, as of 3/29/15, only 36,000 people had done so across the 37 states covered by Healthcare.Gov. A week later, Covered California stated that about 18,000 more had enrolled in the Golden State, for a confirmed total of around 54,000, plus an unknown number in the other 9 states participating (plus DC). I speculated that while things had started off far slower than I figured, they might pick up substantially as the actual April 15th tax filing deadline approached.

Today the HHS Dept. issued a press release reminding people that there's still 10 days left to take advantage of #ACATaxTime...and also threw in an update for HC.gov:

As of April 13, more than 68,000 consumers have taken advantage of this opportunity to sign up for coverage through the Federally-facilitated Marketplace. “We hope uninsured tax filers take the next few days to learn about the options and financial assistance that is available and to enroll in a plan that meets their needs – rather than taking the risk of choosing to get by without insurance for another year.”

Well, so much for a massive last-minute surge (OK, technically there were still 2 days to go before the filing deadline itself, but still). That's 36,000 via HC.gov in the first 15 days and another 32,000 over the next 15 days (3/30 - 4/13). Not only wasn't there a surge, the pace actually slowed down a bit, from 2,400/day to 2,133/day, for an overall average to date of 2,266/day. Meanwhile, California averaged 428/day over a 42 day period (2/23 - 4/05).

Add them together and that's an average of around 2,700/day for 38 states which, combined, comprised 87.7% of the national total QHP enrollments...and 90.7% of the total when you remove CO, ID & MA.

Assuming that this pace is typical of the other 10 exchanges participating that should mean roughly 3,000 people per day nationally, or around 111,000 total as of today (April 20th).

I suspect that this pace will likely drop off even further now that we're over the hump tax filing-wise, but assuming that it stays at roughly a 3K/day rate, that should make the final #ACATaxTime tally up to around 135,000 by April 30th, give or take.

On the one hand, there's no getting around it: This is much lower than I was expecting. On the other hand, again, this was a completely new situation for all involved.

At the very least, this may cause those who have been calling for the Open Enrollment Period to be shifted from autumn to spring in order to coincide with tax filing season to re-think the wisdom of that move.

Then again, the shared responsibility penalty jumped from $95/person / 1% of income up to $325/person / 2% of income this year, and will further go up in 2016, which will likely have a considerable impact on the urgency of signing up during Open Enrollment.

As an aside, remember that the 68K / 111K numbers to date do not include those who are enrolling via the normal "off-season" rules, which allow for people to enroll at any time year-round if they have a qualifying life event such as getting married/divorced, giving birth/adopting a child, moving to a different state or losing their existing healthcare coverage via job loss and so forth. This averaged around 9,000 people per day during the off-season in 2014; I'm ballparking it at around 7,000/day this year to be on the safe side.

However, those 7K/day are also being mostly cancelled out by other people dropping their ACA exchange policies for similar reasons, so while those "count" in terms of total QHP selections, they probably won't move the actual effectuated enrollment needle much one way or the other.

In any event, at the very least, today's news means that the official 2015 QHP selection total has now broken the 11.8 million mark, and is likely around 12.2 million total when those "life event" enrollments are tacked on.

UPDATED: Today I learned that Covered California has updated their #ACATaxTime number to 22,659 as of 4/12, meaning their daily average actually went up a bit to 462/day. That brings the HC.gov + CA average up to 2,728/day, which means the national average should be slightly higher than 3K/day...but I'm gonna leave it at 3K even given the unknowns.