IMPORTANT: I need to stress that I am not in any way supportive of having CSR reimbursement payments cut off. I've written dozens of blog posts for the past year and a half about the danger this poses and I've repeatedly explained why this is a reckless, dangerous move by Donald Trump, I've even repeatedly noted how incredibly easy it would be to resolve the issue with a simple, one paragraph bill. Having said that, assuming the payments do stop being made, this is an explainer of how to turn it into a "lemonade out of lemons" situation for as many people as possible. Make no mistake, however: Millions of people will still be hurt by this...just not the people Trump thinks he's hurting.

Several healthcare wonk colleagues and I have been carefully piecing together the CSR sabotage price loading strategies for every state over the past week or so. This changed from a theoretical exercise to a real one due to Donald Trump officially pulling the plug on Cost Sharing Reimbursement payments effective immediately late Thursday night.

As in most states, the Michigan Dept. of Financial Services, seeing the potential writing on the wall, sent out a memo to all individual market insurance carriers instructing them to submit two different sets of rate filings for 2018: One assuming CSR payments would continue, the other assuming they won't:

Right on top of his potentially devastating executive order this morning (I haven't written up a formal post about it after the fact, but my explainer from a few days ago does a pretty good job of giving the gist), Donald Trump has supposedly finally decided to lower the boom for real on cutting off the legally and contractually mandated Cost Sharing Reduction reimbursement payments to insurance carriers:

President Donald Trump plans to cut off subsidy payments to insurers selling Obamacare coverage in his most aggressive move yet to undermine the health care law, according to two sources.

The subsidies, which are worth an estimated $7 billion this year and are paid out in monthly installments, may stop almost immediately since Congress hasn’t appropriated funding for the program.

UPDATE 10/13/17: Welp. Trump officially lowered the boom on cutting off CSR reimbursement payments last night, so CSR sabotage is no longer a threat, it's a reality (unless there's a court injunction or the GOP-held Congress actually gets off their asses and formally appropriates the payments with a simple, 87-word bill).

Covered California (CA's ACA exchange) just issued the following press release:

Covered California Keeps Premiums Stable by Adding Cost-Sharing Reduction Surcharge Only to Silver Plans to Limit Consumer Impact

  • In the absence of a federal commitment to continue funding cost-sharing reduction (CSR) reimbursements through the upcoming year, Covered California health insurance companies will add a surcharge to Silver-tier products in 2018.
  • However, because the surcharge will only be applied to Silver-tier plans, nearly four out of five consumers will see their premiums stay the same or decrease, since the amount of financial help they receive will also rise. Those who do not get financial help will not have to pay a surcharge.
  • Financial help means that in 2018, nearly 60 percent of subsidy-eligible enrollees will have access to Silver coverage for less than $100 per month — the same as it was in 2017 — and 74 percent can purchase Bronze coverage for less than $10 per month.
  • California and individual markets across the nation still need a clear commitment that the federal government will continue to make CSR payments to promote lower premiums, save taxpayer money and ensure health insurance companies participate.

 

Joint post by David Anderson, Charles Gaba, Louise Norris and Andrew Sprung

Note: This post is a joint effort with colleagues who have closely tracked the CSR chaos induced by Trump and Republicans in Congress. Dave Anderson is a former health insurance analyst, now a healthcare scholar at Duke, and a blogger at Balloon Juice; Louise Norris is co-owner with her husband Jay of a unique health insurance brokerage for individual market customers, and a top source of marketplace information and analysis at her own blog as well as at healthinsurance.org and elsewhere. Andrew Sprung writes about healthcare policy on his blog, xpostfactoid, as well as at healthinsurance.org and other publications.

In August I reported that the three individual market carriers in West Virginia (CareFirst, Highmark BCBS and Health Plan of the Upper Ohio Valley) were requesting average rate hikes of around 17.8% assuming CSR payments are made or 27.8% assuming they aren't.

Today the approved rate hikes came out for the first two. I don't know the final rate for the third company, but they're off-exchange only and have just 133 enrollees, so that won't move the needle one way or the other regardless:

The West Virginia Insurance Commission approved rate increases for Highmark West Virginia and CareSource Insurance’s services sold in the “Obamacare” exchange.

MetroNews learned Tuesday premiums for Highmark West Virginia will increase by 25.6 percent, while CareSource Insurance will have a 19.6-percent increase in its rate.

The article goes on to falsely conflate the 2017 and 2018 rate increases, however:

I noted back in August that there will only be one insurance carrier offering policies on the Nebraska individual market next year (Medica), with Blue Cross Blue Shield dropping out.

Medica originally requested a 16.9% average rate hike, but that was based on the assumption that CSR funding would be appropriated. However, Louise Norris reports that the final, approved average increase will actually be more like 31% due specifically to the lack of guaranteed CSR reimbursements.

Medica has 35,269 members on their ACA-compliant individual market plans in 2017. But all of the current Aetna enrollees, as well as off-exchange BCBSNE enrollees, will need to switch to Medica plans at the end of 2017, as Medica will be the only insurer offering plans in Nebraska’s individual market for 2018.

 

A week or so ago, there was some confusing news about how Donald Trump may or may not be planning on signing a new healthcare-related executive order. I didn't write about it earlier because at first it sounded like he was talking about a meaningless "sell across state lines" decree...meaningless because the ACA already allows carriers to sell ACA-compliant policies across state lines, as long as the states in question sign onto an interstate compact.

More recently, however, it became clear that the executive order in question is more dangerous than I thought:

I was a bit confused by the initial rate hike request for individual market carriers in Kansas, but it seems I was overthinking it. There will be three carriers offering indy market plans this year: Medica, Blue Cross Blue Shield of Kansas and Ambetter (aka Centene, but operating under the name "Sunflower State" here, which is just annoying).

Ambetter ("Sunflower State") is new to the state, so there's no "rate hikes" to speak of. My confusion was regarding BCBSKS, which is already on the KS exchange but didn't appear to submit any actual "rate change" request last time I checked. Louise Norris has cleared up this mystery:

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