New York: The Award for Catch of the Week Goes To...Andrew Sprung!
2019 OPEN ENROLLMENT ENDS (most states)
Time: D H M S
On the one hand, I'm kicking myself for not noticing this red flag when the final 2016 Open Enrollment numbers were released last week. On the other hand, I was trying to absorb, analyze and compile a lot of data at the time, so I should cut myself a bit of slack for missing it.
When the numbers were announced, one figure which seemed surprisingly high was that New York (which still hasn't actually released their final numbers yet) apparently enrolled around 400,000 people in their new ACA-created Basic Health Plan (BHP)...and that 300,000 of these folks had supposedly shifted to the BHP program from existing exchange QHP policies.
This did seem surprisingly high to me; I had assumed that instead of NY's QHP total going up around 25% (as I was expecting in most other states), it would stay essentially flat, with the cannibalization by BHPs essentially cancelling out the 100,000 new QHP enrollees I was expecting. 300K making the move was 3x as many as I was expecting. However, in the flurry of other data to crunch, I let this slip by me.
Fortunately, Andrew Sprung, aka Xpostfactoid, caught it, did an excellent write-up about the weird numbers and had his theory confirmed on Thursday:
Enrollees in New York's Essential Plan, the BHP formed under the auspices of the ACA, come from two pools. The first is those who lack access to employer-sponsored plans and have incomes between 139% and 200% of the Federal Poverty Level (FPL). If the Essential Plan did not exist, these people would be eligible for subsidized QHPs in New York's private marketplace. Some of them were in fact enrolled in QHPs in 2015, but not 300,000.
The second pool is comprised of legally present non-citizens with incomes anywhere from 0-200% FPL who are subject to the federal "5-year bar" on Medicaid eligibility -- that is, you're not eligible for Medicaid until you've been in the country for 5 years. The ACA allows those subject to this Medicaid bar to buy subsidized QHPs even if their income is below the Medicaid eligibility threshold for those not subject to the bar. In New York, however, those subject to the 5-year bar who otherwise meet Medicaid eligibility criteria are eligible, because a court order mandated the state to cover them. Forming the BHP enabled the state to transfer these Medicaid enrollees to a federally funded program. In April 2015, the state did just that, transferring 225,000 lawfully present non-citizens from state-funded Medicaid into the newly formed Essential Plan (open only to this group until January 1, 2016).
The irony here is that Sprung informs me that he actually found the link regarding the April 2015 225K non-citizen Medicaid/BHP transfer via...my own post from about a month ago:
Jonathan LaMantia, healthcare reporter for Crain's New York Business, sent the source link for a story he wrote earlier this year which states that 225K documented immigrants were indeed already quietly transferred over to the BHP way back in April 2015...and estimated that about 200K who would otherwise enroll in exchange policies would likely sign up for the program. That, again, is only 425,000 people. Even allowing for miscalculations, you're still only talking about a half-million or so.
Again, in the craziness of last week, I completely forgot about this even though I wrote those very words just last month!
Anyway, Sprung further crunched the numbers and concluded that only around 148,000 NY QHP enrollees would even be eligible to move to BHPs, based on 40% of the 370K QHP enrollees as of last June. I'm going to reclaim a bit of my dignity here by going him one further: The September 2015 effectuated enrollment report had New York down slightly further still, to 357,000. 40% of that would be around 140K.
Since the total BHP enrollment is apparently around 400K, and around 225K of that is presumably still made up of non-citizens previously transferred from Medicaid, that leaves just 175K who could possibly have already been QHP enrollees.
As Sprung noted today, as it happens, the official CMS Weekly Snapshot has indeed been updated as follows:
about 160,000 of the roughly 300,000 New York Basic Health Program re-enrollees for 2016 were enrolled in Qualified Health Plans last year and were included in last year’s Marketplace total plan selections.1
This suggests that only around 15,000 BHP enrollees came from the ranks of the currently uninsured. It also means that I wasn't nearly as far off in my original "cannibalization" estimate (160K) as I thought (100K).
None of this really changes anything else, mind you; those 225K transferrees being shifted is still a smart move financially for New York, and it's still 400,000 people being covered; it's just not quite as dramatic a launch to the NY BHP program as it first appeared, that's all.
Anyway, kudos to Sprung for the catch and confirmation!