OK, OK, I know I said I was sick of writing about MLR rebates, but there's one more important point I need to mention...and while I'm at it, I also said "to hell with it" and recompiled the rebate tables for all 50 states into a single massive table listing every carrier offering rebates in every state.

While I applaud the ACA's Medical Loss Ratio Rebate provision overall, there's one important flaw in how it works. I've made allusions to this before, and last week David Anderson wrote a blog post specifically about it, but it bears repeating here: Due to an oversight in the wording of the section of the ACA devoted to laying out MLR rebates, some subsidized individual market enrollees are actually PROFITING off the program.

The reason why is pretty simple: The individual market MLR rebate payments are sent, in full, to the policyholder regardless of whether or not their premiums are being subsidized by the federal government or not.

One of the interesting quirks of how the Affordable Care Act's enhancement of our crazy patchwork heatlhcare system works is that there's something of a zero-sum game when it comes to enrollment numbers.

For instance, Virginia's ACA exchange enrollment numbers dropped by 18% this year, from 400,000 to 328,000, due primarily to the state finally getting around to expanding Medicaid to enrollees earning less than 138% of the Federal Poverty Level. Since people earning between 100-400% FPL are eligible for ACA subsidies if they enroll through the exchange, that means there's an overlap for those in the 100-138% range which these folks fell into. The same thing happened in Louisiana, even more dramatically, after they expanded Medicaid halfway through 2016...the following year exchange enrollment dropped by 33%.

Last month I noted that North Dakota had posted their requested 2020 premium rate change requests, including two different filings: One assuming the states' ACA Section 1332 Reinsurance Waiver didn't get approved, the other assuming it did. It was pretty unlikely that their waiver would be denied, however, so the general assumption was that they'd be looking at a significant rate reduction, especially compared with the rate increase if the waiver didn't go through.

At the time, I didn't have access to the actual enrollment figures for the three carriers on North Dakota's individual market, so I had to go with an unweighted average rate change, and came up with a drop of 7.9%.

Since then, however, the state regulators have reviewed and approved the 2020 premium changes, and thanks to Louise Norris, I don't even have to dig up the enrollment data:

Average rates dropping by nearly 6% in 2020 (without reinsurance, they’d have increased by nearly 15%)

In mid-July, the Connecticut Insurance Dept. reported that average requested premium rates for 2020 averaged around a 7.8% increase on the Individual market and 12.0% on the Small Group market.

This weekend, they reported the approved 2020 rate changes for both markets...and have cut down the rate hikes significantly for most carriers (while raising them a bit on a few others):

Insurance Commissioner Issues Decisions For 2020 Health Insurance Rates

Insurance Commissioner Andrew N. Mais today announced the Department has made final decisions on health insurance rate filings for the 2020 coverage year. As a result of these decisions, Connecticut consumers are projected to save approximately $54 million.

Back in early June, the Washington State Insurance Commissioner announced that preliminary rate filings for the ACA individual market in 2020 were averaging just 1.0% higher than this year. My own analysis brought the weighted average in at 1.4%, but whatever. The Small Group market requests also came in at an average increase of 6.7%.

A couple of days ago, the WA Insurance Dept. posted a press release with the final/approved rates for 2020, and they've managed to knock average premiums on the Individual market down by about 4 more points:

Kreidler approves record low average rate decrease of -3.27% for Exchange plans

Eight health insurers approved to sell in next year's Exchange marketplace

With my big MLR Rebate project finally out of the way, I have a backlog of other write-ups, including several approved 2020 premium rate changes. First up is tiny Rhode Island.

As you may recall, back in July the Rhode Island insurance commissioner announced that the state was following New Jersey's model: They're reinstating the individual mandate penalty, and using the revenue from that to help fund their just-approved state reinsurance program to reduce unsubsidized premiums by 5-6 percentage points:

If approved, Rhode Island would have a $14.7 million reinsurance program for 2020 funded through the individual mandate penalty and federal pass-through funding. Rhode Island estimates a federal pass-through rate of 43 percent. Of the $14.7 million, the federal government would contribute less than half of the funds (about $6.4 million), and the state would contribute about $8.3 million.

If you've been reading the site recently, you know that I've been obsessed for the past 2-3 weeks with nothing but the 2018 Medical Loss Ratio rebate payments.

Now that I've completed posting my analyses of all 50 states (+DC), I'm wrapping it up with a table summarizing the the totals for the entire country, how it compares with the Kaiser Family Foundation's similar report posted a few days ago, and some additional thoughts and observations which have come to mind in doing this project.

First of all, as noted, the Kaiser Family Foundation published their own report analyzinng the 2018 MLR rebates when I was about halfway done posting my own state-by-state analyses. They made sure to give me a nice shout-out, anyway:

We at KFF put out an analysis today of how much insurers will be paying in rebates to consumers and employers later this month. @charles_gaba also has very good information on this, and we all benefit from his tireless tracking. https://t.co/uPX2SPklcY

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

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