Idaho: Advertising revenue for Your Health Idaho exchange?

I don't write about Idaho much, which is a bit surprising when you think about it because it's kind of a unique state when it comes to the ACA exchanges. Most states never set up their own exchange platform. A dozen or so set them up and are still using them. Two states (Massachusetts and Maryland) scrapped their original, failed platforms and completely overhauled them. Three states started out with their own platform but gave up when they failed, moving home to the mothership (HealthCare.Gov). One state, New Mexico, was supposed to move off of HC.gov after the first couple of years, but changed their mind and is still hosted by the federal platform. Oh, and there's also Kentucky, which is scheduled to scrap their perfectly-functioning tech platform for absolutely no good reason other than the petty whim of their new Governor, Matt Bevin.

And then there's Idaho.

Idaho is unique for a couple of reasons: Not only is it the only state to start off hosted by HC.gov and then move off of the federal tech platform onto it's own system, it's also the only state running it's own full exchange which hasn't expanded Medicaid as well.

In addition, it's worth noting that while most of the other state exchanges (past and present) experienced serious technical problems and other logistic headaches when they first launched (I think Kentucky and Connecticut are the only ones which have operated smoothly since day one), Idaho's exchange, Your Health Idaho, seems to have gotten it right from the get-go, quietly launching with minimal drama for the 2nd year of ACA open enrollment in 2015.

Anyway, I stumbled upon their executive board meeting minutes from back in June, and this section caught my eye:

(c) Revenue Opportunity

Mr. Kelly said we have discussed a number of times the need for additional revenue sources. As part of our move to bring resources in-house, we absorbed ownership of the front end of the website. By front end, I am referring to the pages consumers see before they log in.

YHI has high traffic volumes which is very attractive to advertisers. It is measured as gross impressions, or the number of people viewing a website. It is important that we establish a policy so that those advertisers fit with the mission and compliance of the health exchange.

Potential revenue projections show that if we charged a small fee for every one-thousand impressions, we could host up to 30 advertisers. Revenue estimates show YHI could generate between $100-300 thousand dollars in the first 12 to 18 months. The best part is that website advertising would involve a minimal investment of less than $20K, bringing an immediate and positive return on investment.

The next steps are to formalize the rate structure, review the software options that allow for banner ads on key web pages, define the parameters for types of advertisers and create a list of potential buyers, and finally, we would make certain that Privacy and Security requirements are met through all of this. We would then bring our final proposal to the Board in September.

Mr. Edgington stated that the timing on this advertising as a potential revenue stream, if brought to the board in September, would be tight. Mr. Kelly said assuming the Board endorses the proposal in September, YHI would target October 1 or November 1 to begin. The pipeline would be built prior to the Board meeting in September and then YHI would execute following approval.

Ms. Henbest said her first reaction is distraction to the consumer, and wondered what kind of feedback, if any, we have received from other state-based exchanges. Mr. Kelly said YHI would be the first exchange in the country to have banner advertising on its website and we are working very closely with CMS to ensure they are fully supportive. In terms of minimizing the distractions, there would only be three ads per page, with no pop-ups or overlays.

Mr. Settles asked if YHI had developed a mockup yet. Mr. Kelly said yes, and he will share it following the Board meeting.

Hmmmmm.

I've been under the impression that the exchange websites are simply not allowed to offer banner ads, seeing how they were established by (and initially funded by) federal tax dollars. After all, you don't see banner ads at Medicare.Gov or WhiteHouse.Gov. On the other hand, once the federal grant money has been used up, the exchanges are expected to pay for themselves, and depending on the state, they may or may not be official state government-owned entitites anyway (I think some are run by the state directly, some are semi-independent organizations and some are in between?) It's possible that some type of advertising might be allowed after all.

On the other hand, I could also see a massive conflict of interest here, as well as enrollee confusion. What if Aetna or Humana (or whomever) were to swallow up the ad space...wouldn't that give them a huge unfair advantage on the other carriers offering policies via the exchanges? Aren't the exchanges supposed to act as neutral parties, simply presenting the various carrier offerings equally?

The only way I could see something like this working would be if there were strict rules preventing any of the advertising from being for (or from) any company, product or service in the health insurance field...basically, the exact opposite of what you normally see with a standard Google AdWords system (in which the ads tend to be highly relevant to the website content). I could see allowing ads for, say, a hardware store or auto retailer, but not for insurance policies, medical equipment or medication.

Actually, the more I think about it, it might be more appropriate if the ads were limited to other government agencies/departments. For instance, the Idaho DMV or state health department (obviously) might use some of their budget to advertise on the YHI site?

Anyway, it's an interesting idea; we'll see if anything comes of it.