END OF 2018 OPEN ENROLLMENT PERIOD (42 states)

Time: D H M S

Charles Gaba's blog

For awhile now I've been noting that making predictions about how many people will actually enroll in ACA exchange plans for 2018 is extremely difficult to do for a variety of reasons. On the one hand, Donald Trump has been desperately trying to sabotage the law any way he can, including everything from slashing outreach funding by 90% and cutting the enrollment period in half to cutting off Cost Sharing Reduction reimbursement payments...while at the same time Congressional Republicans have been desperately trying to repeal the law outright. All of this has caused a tremendous amount of confusion, as well as causing average unsubsidized premiums to shoot up around 30% on average nationally.

As both the largest-population state in the country and the largest state-based exchange under the ACA, Covered California provides an important guideline for me when it comes to attempting to track national enrollment data. They hold over 12% of the total U.S. population and enrolled 12.7% of all ACA exchange enrollments for 2017, coming in second only to Florida's 14.4%.

Today I confirmed that on Day One of the 2018 Open Enrollment Period, CoveredCA signed up 5,979 people...around 25% more than they did on Nov. 1st last year.

Over at the Obamacare: What's Next? Facebook group, John Bruder raised an odd premium situation he ran across in Hawaii.

According to our CSR Load Load spreadsheet, Hawaii is supposed to be one of the 20-odd states using the full "Silver Switcharoo" strategy. It also has a single Rating Area, and only has two carriers (Kaiser and HMSA) participating in the individual market (on or off-exchange) anyway, making it a pretty easy state to run a full apples-to-apples year over year comparison.

Kaiser is offering a total of 11 plans on the ACA exchange (3 Bronze, 3 Silver, 3 Gold and 2 Platinum), while HMSA lists 10 (2 Bronze, 3 Silver, 3 Gold and 2 Platinum). I couldn't run a perfect comparison to 2017 since each carrier changed a couple of their offerings, but it's pretty darned close.

*(OK, Maine is a lock...except that GOP Gov. LePage is apparently still being an utter jackass about implementing it, while Virginia is still kind of iffy...see below...)

UPDATE 11/8/17: Maine voters approve Medicaid expansion

Maine voters on Tuesday decided to expand Medicaid to cover more low-income adults, becoming the first state to do so through a referendum.

Support for the ballot measure was up by more than 18 points with 64 percent of precincts reporting about 10 p.m. when it was called by NBC affiliate WCSH and The Associated Press.

The results in Maine, one of 19 states that rejected Medicaid expansion under the Affordable Care Act, comes as other Republican-led states like Utah and Idaho eye similar ballot measures.

Advocates of Medicaid expansion in Maine successfully petitioned the state to include a question on this year’s ballot following several failed legislative efforts to expand the program.

The Washington HealthPlan Finder is the 2nd state exchange to release their initial enrollment data from opening day:

  • We had a very good first day of Open Enrollment
  • Over 32,000 unique visitors and 886,000 page views
  • At peak we had 3,534 concurrent users when on 11/1 last year our peak was of 2,699 concurrent users
  • 2,108 QHP plans selected by customers who either did not have a 2018 enrollment or switched away from the plan they were auto-enrolled into
  • Over 800 new downloads of the WAHBE mobile app
  • No significant system issue was encountered

In addition, unlike the federal exchange and most state exchanges, instead of waiting until after the initial wave of erollments are out of the way, Washington auto-renews existing enrollees right up front, but then changes their policies as people log in and switch to a different policy (or cancels the renewals if people don't pay up or inform them that they're not renewing):

(sigh) A couple of weeks ago, I reported that it appeared that Illinois was joining the ranks of states which were going the full "Silver Switcharoo" route for the 2018 Open Enrollment Period, based on an article by Kristen Schorsch in Crain's Chicago Business:

Even before President Donald Trump announced plans last week to nix Obamacare subsidies, the Illinois Department of Insurance raced over the summer to get insurers on board with a strategy to minimize the financial pain of such a move.

...Trump on Oct. 12 ordered the federal government to stop paying the cost-sharing subsidies provided to insurers to defray the cost of covering low-income people. But the Rauner administration has found a way to make the federal government pick up the tab anyway.

Believe it or not, the original core focus of ACASignups.net was...wait for it...to track how many people are Signing Up for the ACA. Hard to believe, I realize.

Anyway, I have my first hard data point of the batcrap insane 2018 Open Enrollment Period, and it's a surprisingly positive one:

Enrollments in health insurance through the state’s health exchange was robust on the first day of open enrollment Wednesday, with more people signing up for insurance than last year, officials said Thursday.

Advocates and others had expressed concern that consumers would be confused by political wrangling and policy changes to the Affordable Care Act from the administration of Pres. Donald Trump that led to last-minute rate increases and a severe decrease in marketing dollars for the program.

But exchange officials reported that enrollments under the law, known as Obamacare, were up 70 percent to more than 1,800 compared with 1,055 on the first day a year ago. About 150,000 people signed up for private insurance on the exchange in the state last year and more enrolled directly through insurers.

Until today, I operated under the assumption that my home state of Michigan was among the 18 states which took the "Silver Load" approach to dealing with the Cost Sharing Reduction (CSR) cut-off by the Trump administration. Reviewing the SERFF rate filings of the various carriers participating in the individual market, it looked like most of them were loading the CSR cost onto both on and off-exchange Silver plans. I didn't check every single carrier, but that seemed to be the trend, so I filed the state under "Silver Load".

HOWEVER, earlier today, commenter "Cayo" chimed in to say:

I'm signing up for a plan off the exchange with Priority Health in Michigan. ON-Exchange, the plan is $365 a month, but off exchange (directly from their website), the price is $300 per month. I don't qualify for a subsidy, but it's still cheaper than my 2017 plan with BCBSM. That was the Multi-State Plan in Region 7 with Dental and Vision.

MAJOR UPDATE / MEA CULPA: 

Hey there, I called again and I was able to talk to a more knowledgeable agent who found out what the issue was and was able to enroll me in a plan!

Apparently, the Marketplace renewed automatically my application based on my 2016 income, which was enough to receive a tax credit in 2017, but is no longer enough to receive one in 2018.

Luckily, my income has increased since then, so I reported the change and was able to get a credit applied to the premiums

Still need to send copy of my green card for verification, but I can use the tax credit immediately

So I'm not sure why the person I talked to earlier today told me the rules had changed

Sorry for the confusion

OOF. OK, this pretty much torpedoes the entire basis of this blog entry. I'm going to leave it up in the interest of letting documented immigrants know that they ARE eligible to enroll AND for tax credits, but it sounds like the original concern may be unwarranted after all.

No one has been promoting the Silver Switcharoo option (in states which allow it) louder or more emphatically than I have for the past few weeks.

To summarize (again), this is where someone whose household income is too high for them to qualify for ACA tax credits (400% of the Federal Poverty Line) chooses an ACA-compliant off-exchange Silver plan instead, which is either identical or nearly identical to the same on-exchange policy in every way except that the additional CSR load hasn't been tacked onto it.

Here's a perfect example found by Louise Norris...ironically, this is via Priority Health here in Michigan, which (until today) I thought was a "Silver Load" state, not "Silver Switcharoo". I'll have to do some more research to be sure, but it sounds like at least one MI carrier (Priority) is going full Switch:

#1: The 2018 Open Enrollment Period is only half as long as usual in most states!

  • In the other 11 states (+DC), the deadline to enroll for 2018 coverage is later...but the final dates range from Dec. 22nd (CT) to as late as Jan. 31 (CA, DC & NY).

#2: BOTH types of Tax Credits/Subsidies ARE STILL AVAILABLE for those who qualify!

UPDATE: It looks like this issue may be limited to a single carrier in New Mexico; I've changed the headline and graphic accordingly...but it might be an issue in other states as well; if so I may have to change it back again...

Fantastic (if migraine-inducing) scoop by Susannah Luthi of Inside Health Policy (paywall):

Insurers That Filed Wrong Rates Told By CMS They Can't Sell Plans Through Mid-November

An issuer whose final CMS-approved rates don’t account for the loss of cost-sharing reduction payments is being told by the agency that they won’t be able to sell plans until healthcare.gov data is refreshed– even though this would mean the carriers are even more crunched for time to sell their plans during the shortened open enrollment period.

Last week I gave a very rough, back-of-the-envelope projection of perhaps 9.5 - 10.0 million Qualified Health Plan (QHP) selections during the 2018 Open Enrollment Period, which starts tomorrow. As I repeatedly emphasized, this wasn't based on any deep-in-the-weeds statistical analysis, because the one-two punch of the GOP's farcical "repeal/replace" efforts combined with the Trump Administration's "let Obamacare explode!" sabotage efforts have managed to botch things up so badly that I didn't see much point in expending the effort this year. Besides, others, such as Obama Administration Chief Marketing Officer Joshua Peck have already done part of this work for me:

Considering how absolutely obsessed the Trump Administration is about repealing the ACA, this new official report from Trump's Assistant Secretary for Planning and Evaluation (ASPE) seems like a strange way of showing it.

The very first bullet starts off ripping on the 37% average rate hike on benchmark Silver plans...

Benchmark Premiums: The average monthly premium for the second-lowest cost silver plan (SLCSP), also called the benchmark plan, for a 27-year-old increased by 37% from plan year 2017 (PY17) ($300) to PY18 ($411).

Premium Growth: For the first time, annual growth in the average monthly premium available to a 27- year-old for the SLCSP, at 37%, outpaced that of the lowest-cost plan (LCP), at 17%.

Of course, there's pretty obvious reason for that: Trump's cut-off of Cost Sharing Reduction (CSR) reimbursement payments. The ASPE report does go into this, but not until Page 6. Meanwhile, it's immediately undermined anyway (at least regarding subsidized enrollees) in the very next bullet:

With the 2018 Open Enrollment Period coming up just 5 days from now, it's time to put this to bed: After 6 months of painstaking research and analysis, I've compiled a comprehensive analysis of the weighted average rate changes for unsubsidized ACA-compliant individual market policies in 2018, including both the on- and off-exchange markets. It's already been confirmed by a different analysis by healthcare consulting firm Avalere Health, which used a completely different methodology to arrive at the exact same conclusion: The national average increase is between 29-30%, ranging from as low as a 22% average premium drop in Alaska (thanks to their successful reinsurance program) to as high as a painful 58% increase in Virginia.

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