OE6

2018 MIDTERM ELECTION

Time: D H M S

Given how progressive Vermont is, you'd think that they'd be doing as much as possible to batten down the hatches in order to avoid or mitigate the latest wave of sabotage efforts from the Trump Administration and the GOP...and you'd mostly be correct.

Some of the work on that front has already been done. For one thing, Vermont (along with Massachusetts and the District of Columbia) merges their individual and small group market risk pools together, which helps smooth out premium increases and overall morbidity across a larger risk pool. For another, Vermont has fully embraced ACA provisions such as Medicaid expansion and operating their own full exchange, of course. Vermont, along with a few other states, also has pretty strict rules in place limiting both short-term and association healthcare plans, so that portion of Trump's sabotage attack is neatly cancelled out already.

Louise Norris is an awesome source for all sorts of healthcare policy/insurance data, but she's especially on top of developments in her home state of Colorado, where she and her husband Jay run a small brokerage outlet.

Today Jay and Louise have a couple of interesting tidbits out of The Centennial State (yeah, I had to look up their nickname myself).

First, according to Jay (via the Connect for Health Colorado exchange itself), as of May 7, 2018, C4HCO had exactly 142,474 people enrolled in effectuated ACA exchange policies statewide. This is noteworthy mainly because 161,764 people selected Qualified Health Plan (QHP) policies during the 2018 Open Enrollment Period.

That's (sort of) an 88% retention rate through early May. I say "sort of" because this presumably includes some amount of churn (if 100 people drop coverage and 100 off-season enrollees sign up, that'd be a net change of zero). Even so, it's actually slightly better compared to prior years, when the national effectuation number had usually dropped to around 87% by the end of March.

Hot on the heels of Virginia, Maryland is the 2nd state to post their preliminary 2019 unsubsidized ACA policy rate increase requests. According to Paul Demko of Politico...

Insurers selling Obamacare plans in Maryland are again seeking huge rate increases for 2019, but they could be knocked down significantly by a reinsurance program the state hopes to implement for next year.

CareFirst BlueCross BlueShield wants to increase rates on average by 18.5 percent on its HMO plans, which account for more than half of the individual market this year. Kaiser Permanente, the only other insurer selling on the exchange, is seeking a 37.4 percent average increase on its HMO plans, which cover just over a third of Obamacare customers.

A couple of days ago, I posted that Virginia has become the first state out of the gate with their preliminary 2019 premium rate requests for ACA individual policies. However, I made sure to emphasize that these are preliminary requests only; carriers often resubmit their rate change requests more than once over the course of the summer/fall, and even that may not match whatever the final, approved rate changes are by the state insurance commissioner.

In addition, I generally try to make it understood that there's alotof room for error here--the weighted averages are based on the number of current enrollees, but of course that number can change from month to month as people drop policies or sign up during the off-season (via Special Enrollment Periods). Even then, the rate filing paperwork is often vague or confusing about just how many enrollees they actually have in these plans. Sometimes wonks are reduced to taking the number of "member months" and dividing by 12 to get a rough idea of how many people are enrolled in any given month. Sometimes the only number of enrollees available are from last year, which could bear zero resemblence to how many are currently enrolled. Sometimes the only number available is how many people the carrier expects to enroll in their policies next year. And so on.

Aside from Virginia, it's likely going to be another month or so before the 2019 ACA policy rate filings start trickling in, since the deadline for initial rate requests isn't until late June in most states. However, there's some interesting non-ACA policy filing stuff which is available as well. Given all the concern about non-ACA compliant policies siphoning healthy people away from the ACA market, I figured I should take a look at a few of these.

Here in Michigan, I've found three such filings: One is for "transitional" plans from Golden Rule (a subsidiary of Unitedhealthcare, I believe). The other two are for "short-term" plans (the type which Donald Trump is basically removing any regulation on).

First up, Golden Rule:

IMORTANT UPDATE: As I suspected, it turns out that the stray rate filing posted to the California Insurance Dept. website a few days ago was posted prematurely, doesn't reflect the carrier's final* rate filing, and has since been pulled from the California Insurance Dept. website.

I've been asked to remove the filing data, and seeing how there's nothing nefarious about it (I wasn't "whistleblowing" evidence of anything criminal/unethical), I'm complying with that request. Since everything in the post related to that data, there wasn't much point in keeping the rest of it either.

*(Yes, I'm aware that none of these early filings are "final" since they tend to be revised/resubmitted throughout the summer/fall, but you know what I mean.)

Covered California Analysis Shows Major Declines in New Enrollment Nationally and Identifies Policies That Could Lower Premiums in 2019

  • Enrollment in the federally facilitated marketplace has dropped 9 percent over the past two years, with a nearly 40 percent drop in new enrollment, while enrollment in state-based marketplaces remained steady during the same period.

Nothing new under the sun here; this is the core of what I do at ACASignups.net. In fact, this press release underplays the point slightly: The official enrollment tallies are down 10% on the federal exchange since 2016 and up 1.5%, although the discrepancy might be partly due to Kentucky shifting from state-based status to federal status in 2017.

A few weeks ago I posted an entry title, "Will Trump's HHS Dept. do the stupidest thing possible? Reply Hazy; Try Again Later."

The "stupidest thing possible" being referred to was whether or not CMS Administrator Seema Verma is planning on putting the kibosh on Silver Loading and the Silver Switcharoo starting in 2019:

The head of the Centers for Medicare and Medicaid Services would not say Thursday if the Trump administration is considering setting limits on how insurers that sell Obamacare plans structure subsidies for their customers.

"I'm not going to comment on the agency's deliberations," CMS Administrator Seema Verma said when asked by the Washington Examiner about rumors that had circulated about the issue. When pressed about whether any conversations had occurred, Verma said, "I'm just going to leave it at that."

Last month I noted that while Congressional Republicans spent all of 2017 desperately attempting to "blow up" the Affordable Care Act via a combination of legislation, the Trump Administration simultaneously tried to tear down the law via various regulatory sabotage efforts. This year the GOP Congress appears to have mostly given up on their mischief (they did manage to partially wound the ACA by repealing the individual mandate), the Trump Administration is doubling down on regulatory sabotage, laying what I've termed "Regulatory Siege" to the law.

In my mind, "phase one" included the non-legislative stuff Trump did last year, including stuff like cutting off CSR reimbursements, slashing the Open Enrollment Period in half, slashing marketing funding by 90%, slashing the outreach budget by 40% and so on. "Phase two" includes the previously-announced #ShortAssPlans executive order, CMS allowing work requirements for Medicaid and so forth (individual mandate repeal belongs here as well, although that was legislative, not regulatory...although there's overlap as you'll see below).

Yesterday brought Phase Three.

Maryland Governor Larry Hogan signed a bipartisan bill on Thursday that state officials say will help keep healthcare premiums from spiking again next year.

The bill creates what’s known as a reinsurance program for the state’s health insurance marketplace, which was created as part of the Affordable Care Act.

...Without the fix or any action in Washington, Maryland officials predicted that healthcare premiums in 2019 could jump up to 50 percent, driving more of the 150,000 people to abandon the state’s marketplace — possibly leading to its collapse.

 

Yesterday morning, Larry Levitt of the Kaiser Family Foundation posted this tweet:

Our polling suggests the public is most likely to blame President Trump and Republicans in Congress for any problems in the insurance market going forward.

— Larry Levitt (@larry_levitt) March 26, 2018

Something about this pie chart seemed awfully familiar to me...

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

Two pieces of welcome news out of the Green Mountain state via Louise Norris at healthinsurance.org:

New legislation will allow Vermont insurers to load cost of CSR only onto on-exchange silver plans for 2019

For 2018 coverage, Vermont, North Dakota and the District of Columbia were the only states that didn’t allow insurers to add the cost of cost-sharing reductions (CSR) to premiums after the Trump Administration cut off federal funding for CSR. In most states, insurers were allowed to either add the cost of CSR to all silver plan premiums, to all on-exchange silver plan premiums, or, in a few cases, to all metal-level plan premiums. But in Vermont, North Dakota and DC, insurers simply had to absorb the cost of CSR, estimated at $12 million a year in Vermont.

As a reminder, for 2018:

OK, this is just kind of...odd.

As regular readers will recall, after three years of full 3 month Open Enrollment Periods across every state, last year the Trump Administration slashed the official Open Enrollment Period in half, down to just 6 weeks, from November 1 - January 31 down to November 1 - December 15th.

In response, most of the state-based exchanges announced that they were sticking with a longer period anyway, ranging anywhere from a 7th week all the way out to the full 3 month period, in the case of California, New York and the District of Columbia...each of which kept things going all the way through January 31st as had become the norm.

California even went one step further, passing a state law specifically mandating a 3-month Open Enrollment Period for 2018 and beyond.

Until today, I've been operating on the assumption that they'd be sticking with the November/December/January schedule which had become the default.

Apparently not, however. According to Louise Norris:

As long as I'm snarking on Washington's exchange for getting so excited over what appear to be pretty minor tweaks (to the average Joe, anyway), I might as well also give a shout-out to Connect for Health Colorado as well, which just posted this tidbit:

To Our Valued Stakeholders,

We took an important step forward this week with our board’s decision to move ahead on building a new eligibility system. With our own system, we will be able to provide customers a better application and enrollment experience and at the same gain more control and predictability for IT expenses.

A simplified path for enrolling with financial help can be expected to help us grow enrollment while getting more Coloradans the Advance Premium Tax Credit and Cost Share Reduction benefits that they are eligible to receive. We will continue to support Health First Colorado (Medicaid) enrollments and ensure that customers are routed to the right program, whether they begin at our site or with the PEAK application.

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