CSRs

2018 MIDTERM ELECTION

Time: D H M S

Welp. The Congressional Budget Office just released their latest 10-year economic outlook. There's a whole mess of stuff in there, but let's focus in on one area of particular interest to the healthcare wonk community:

Health Insurance Subsidies and Related Spending. Outlays for health insurance subsidies and related spending are estimated to increase by $10 billion, or 21 percent, in 2018.8 That jump mostly stems from an average increase of 34 percent in premiums for the second-lowest-cost “silver” plan in health insurance marketplaces established under the Affordable Care Act. (Those premiums are the benchmark for determining subsidies for plans obtained through the marketplaces.) Over the 2019–2028 period, the average growth in spending is projected to lessen considerably, to just under 5 percent per year, as per-beneficiary spending rises with the costs of providing medical care. CBO estimates that, under current law, outlays for health insurance subsidies and related spending would rise by about 60 percent over the projection period, increasing from $58 billion in 2018 to $91 billion by 2028.

Yup, thanks to deliberate sabotage from the first two years of the Trump Administration, premiums have spiked by ~30% this year and will do so again next year, requiring federal spending on subsidies to increase accordingly.

Regular readers know that I've developed a tradition over the past three years of tracking the average unsubsidized premium rate increases for the ACA-compliant individual market, painstakingly poring over the rate filings for every carrier in every state and running a weighted average by their market share.

Every year there are numerous challenges and headaches which get in the way, including things as obvious as "not every carrier publishes the number of enrollees they have covered" to complex situations like "carrier X is dropping out of the on-exchange market in half the counties of the state but is sticking around in the off-exchange market". In addition, many carriers submit an initial rate request...followed a few months later by a revised one...neither of which might end up matching the final premium changes approved by state regulators. Sometimes there may be 2-3 more revised filings along the way which muddy the waters even further.

NOTE: I've modified the headline to clarify that it's CSR reimbursements which are dead, not the actual CSR subsidies. Those eligible for CSR assistance will still receive it from the insurance carriers..it's just that the carriers aren't/won't be reimbursed for doing so. In response, they've jacked up the premium rates on others to cover their losses.

And in the end...neither Alexander-Collins, Alexander-Murray, Collins-Nelson or any other "ACA stabilization bill" was included in the final version of the "must-pass" omnibus bill last night.

As I understand it, this means that unless a standalone bill of some sort passes, there will be no significant legislative changes to the ACA exchange/individual market status for the 2019 Open Enrollment Period at the federal level...and that's extremely unlikely to happen this year.

A few days ago I warned Congressional Democrats that while I agree that appropriating CSR reimbursement payments at this point would be a net negative move thanks to the clever Silver Load/Silver Switcharoo workaround developed last year, there's one possible cloud surrounding that silver lining, so to speak: What if the Trump Administration were to attempt to put the kibosh on Silver Loading altogether?

I don't know the legality of such a move, mind you, but It has been thrown around the rumor mill of late, so I figured I should remind them to keep that possibility in mind.

Well, today I received some reassurance...

Azar Says He Is Not Aware Of Discussions On Blocking ‘Silver-Loading’ in 2019

I just did a light analysis of how many people would be helped or hurt by CSR funding in 2019 in Rhode Island, and concluded that at least 28% of exchange enrollees would see their premiums increase if CSR funding was restored, while only perhaps 2-3% would see their premiums drop.

It turns out that over the weekend, my colleague Xpostfactoid did a much deeper analysis of the same situation in Maryland:

So there you have the enrollment results of full-bore on-exchange silver-loading of CSR costs in one state. In all, 49,993 on-exchange enrollees with incomes up to 400% FPL chose plans other than silver. About 48,000 of them were subsidized. That's 31.2% of all enrollees, within striking distance of Aron-Dine's upper bound of 36% for all marketplace enrollees.

This is exactly what Dave Anderson, Colin Ballio and I have been talking about for awhile now:

Under the Guise of “Health Insurance Stabilization,” Congress Should Not Axe Financial Help for Low-Wage Families

In negotiations over stabilizing the individual health insurance market, lawmakers are considering slashing federal health care assistance for low- and moderate-income consumers by more than $27 billion a year. In dollars terms, this would be a greater blow than completely eliminating, in one stroke, the Low-Income Home Energy Assistance Program, the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), the Child Care and Development Block Grant, the Community Development Block Grant, and federal grant programs for community-based mental health services and substance abuse prevention and treatment.

 

via Caitlin Owens of Axios...

Sens. Lamar Alexander and Susan Collins have proposed a market stabilization package that would include funding for the Affordable Care Act's cost-sharing reduction subsidies for three years, three years of federal reinsurance at $10 billion a year, additional ACA waiver flexibility for states, and expanded eligibility for "copper" plans.

Alexander presented the plan yesterday to America's Health Insurance Plan's board of directors, adding that if Democratic leadership supports the bill, “it’ll be law by the end of next week." Alexander has long said the package should be included on the omnibus spending bill.

Last fall, Dem Senator Patty Murray and GOP Senator Lamar Alexander (among the few Republican Senators actually interested in improving the ACA) got together and hammered out a deal called Alexander-Murray. At the time, the bill would have done the following:

  • Two years of subsidy funding, along with funding for the rest of 2017. There will also likely be additional steps to help enrollees with their premiums in 2018.
  • A "copper plan" for people older than 30, which would be less comprehensive than other ACA plans but would have a lower premium.
  • $106 million in enrollment outreach funding in 2018 and 2019.
  • Shorter review time for states seeking waivers from some of the ACA's coverage requirements. It's unclear what other waiver changes have been agreed to at this time.
  • Authorization for funding to help states launch reinsurance programs, which would defray the costs of covering the sickest consumers.

Of these five items, it's really the first two which would have the biggest impact: CSR reimbursement payments and a low-end "Copper Plan".

SOME GUY, OCTOBER 2017:

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.

Healthcare reporter extraordinaire Margot Sanger-Katz has been picking through the horror show known as Donald Trump's proposed annual federal budget, and it's every bit as awful as you might expect:

The first one I already wrote about this morning...

The White House’s preferred Obamacare replacement now appears to be Graham-Cassidy.
https://t.co/stjZMYSeMO pic.twitter.com/wS62MkbgVp

— Margot Sanger-Katz (@sangerkatz) February 12, 2018

In a surprise to no one, Planned Parenthood would appear to be defunded...

This would be a big policy change. pic.twitter.com/1UoylIyHRJ

Remember this from a few weeks back?

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 refreshedeven though this would mean the carriers are even more crunched for time to sell their plans during the shortened open enrollment period.

Me, just under a month ago:

Things were looking pretty dicey for two of Montana's three insurance carriers participating on the individual market the past few days. One of the three, Blue Cross Blue Shield, saw the writing on the wall regarding Cost Sharing Reductions (CSR) likely being cut off and filed a hefty 23% rate hike request with the state insurance department. The other two, however (PacificSource and the Montana Health Co-Op, one of a handful of ACA-created cooperatives stll around), assumed that the CSR payments would still be around next year and only filed single-digit rate increases.

I'm not going to speculate as to the reasons why they both did so when it was patently obvious that having the CSRs cut off was a distinct possibility, although I seem to recall the CEO of the Montana Co-Op said something about their hands being tied since CSR reimbursement payments are legally required, after all. Basically, it sounds like he was genuinely trying to avoid passing on any more additional costs to their enrollees than they had to.

Just taking a moment to pat myself on the back. Here's my final estimate of the average unsubsidized 2018 premium increases nationally, along with a rough breakout of the reasons for the increase:

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.

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.

(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.

Pages