Your Health Idaho launches banner ads...
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.
Anyway, at the time I also noted that Your Health Idaho was considering allowing banner ads on their exchange website:
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.
Well, as you can see if you visit their site, it looks like they decided to go ahead with the banner ad program after all. However, they addressed my concerns as shown in their September board meeting minutes:
15. REVENUE OPPORTUNITY
Mr. Kelly stated that as a reminder, YHI has been evaluating revenue opportunities around digital advertising. The general approach is to implement low impact advertising on the front-end of our website. The front-end is defined as pages prior to the customer logging into their account. YHI believes it is imperative to keep the ads separate from the actual enrollment process to maintain independence.
Ads will be placed in three areas of the website pages: across the top and down both the right and left sides. A single ad in each location such that the total number of ads is never greater than three. This will help maintain the clean look of the website.
YHI leadership has completed the vetting process for the digital advertising revenue opportunity. Numerous conversations have taken place with CMS, legal counsel and other key stakeholders.
Mr. Kelly reviewed the three primary areas of focus. First, it was imperative to maintain independence and ensure no digital advertisements created a sense of endorsement or preference by YHI. As such, YHI will implement an interstitial pop-up that will inform the user that by Page 10 of 11 clicking “ok”, they are leaving YHI’s website and that YHI does not endorse any third party advertisers. YHI will maintain acknowledgement history in case it is needed in the future.
Second, YHI’s digital advertising policy outlines who can advertise and what content is restricted. Each advertiser and their content will be reviewed internally at YHI prior to publishing to ensure compliance with the digital advertising policy. Advertising buys by carriers will be restricted to ensure that each carrier has an equal opportunity to advertise.
Sure enough, if you click one of the ads you see this first:
Oh, one other tidbit from YHI's board meeting:
a) Grant Funding and Enrollment Highlights
Mr. Kelly said at of the end of July, YHI had about $13.6M remaining from the original grant awards. Since the end of July, there have been a number of payments related to the Support Center integration as well as enhancements in the technology. The current grant balance is approximately $12.2M. Given the current level of investment in establishment activities, YHI plans to submit a No Cost Extension for these funds to remain available into 2017.
Mr. Kelly said YHI’s effectuated enrollments declined slightly to 94,426. This decline is in line with previous year’s seasonal declines. Overall, YHI remains ahead of its enrollment projections driving revenue favorability for the financial year ended June 30, 2016. As a side note, YHI’s lower Assessment Fee has resulted in savings of over $13M for Idahoans when compared to the federal fees.
In other words, Your Health Idaho is actually chugging along quite smoothly, in part because they're running their own exchange and taking the job of doing so seriously.