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King v. Burwell: Actual # of people at risk of losing tax credits is 100,000 higher than everyone thinks.

I talked about this in my "overperformers/underperformers" entry last night, but I think this point got kind of lost in the shuffle, so I'm devoting a full entry to it.

Yesterday's giant data dump from the CMS division of the HHS Dept. noted that as of March 31st, 2015, 6,387,790 people were receiving APTC (Advance Premium Tax Credits) across the 34 states at risk of losing those credits due to the King v. Burwell court case. That's the number of people who were actively enrolled in paid-for, effectuated policies as of 3/31/15. Fair enough.

HOWEVER, regular readers will note that while my official table from a week or so ago gave a nearly identical estimate (6.43 million), I've actually been using a higher number (6.5 million) for general discussion ever since mid-April. There's a reason for this.

As I noted last night:

The CMS numbers are as of March 31, while my own estimates are projections as of July 1st, the first day which the tax credits could potentially be removed.

Why is this important? Because while the normal off-season QHP additions are likely being cancelled out by other people dropping their policies, there's an additional 214,000 or so private enrollments which aren't included in CMS's 10.19 million total.

How do I know this? Because while around 48,000 people selected a plan via the Tax Filing Season Special Enrollment Period between 3/15 - 3/31 (36,000 on HC.gov, perhaps 12,000 more across the other 11 participating states), none of those policies became effectuated until May 1st. In addition, another 166,000 #ACATaxTime enrollments came in during April, which again, wouldn't be counted until May 1st and thus shouldn't be part of today's 10.19 million figure.

In other words, when you include the additional enrollments which came in between 3/15 - 4/30, the national total will likely be around 180,000 higher as of the end of the June...or roughly 10.38 million.

The good news is that this is about 300,000 people more than I've been estimating until now.

The bad news is that this also means roughly 105,000 more people who would lose their tax credits in the event of an adverse King v. Burwell ruling:

  • 147,000 of the #ACATaxTime enrollments were via HealthCare.Gov.
  • Assuming that about 3% of those were in Nevada/Oregon/New Mexico, that leaves around 143,000 in the other 34 states.
  • Further assuming that about 87% of those are paid & effectuated by the end of June (10.2 / 11.7 = 87%), that leaves 124,000.
  • Finally, assuming 85% of those are receiving tax credits by the end of the month, that's an extra 105,000.

Unfortunately, HHS never provided a state-by-state breakdown of those 147K "tax enrollment" additions, but assuming that they're spread out proportionately relative to the other enrollments by state, the 105K receiving tax credits should add roughly 1.6% to the tally for each one.

In other words, instead of Florida having 1,324,516 people at risk starting on July 1st, it's probably more closer to 1,345,000, or over 21,000 more people. Instead of Texas having 832,334 at risk, they're probably closer to 845,600, and so on.

Just wanted to throw that out there.