At long last, the final piece of the puzzle can be added: I just received the final 2019 Open Enrollment Period numbers from Vermont Health Connect.
Before looking at it, it's important to understand that Vermont has a unique way of reporting ACA-compliant healthcare policy enrollments.
For the first two years of Open Enrollment, the state didn't allow any off-exchange (or "direct") enrollments for the individual market (or the small business market, I believe). That means all indy market enrollments were done through the exchange. Due to technical problems (and possibly for other reasons as well), however, starting in 2016 they started allowing direct/off-exchange enrollment as well, as every other state does (the District of Columbia is the only other ACA exchange which has no off-exchange market). However, Vermont still requires the insurance carriers to report those off-exchange enrollees to them and they report them as well.
I wish every state reported their enrollment data this way; it would make it much easier for me to do my job, since as it stands the off-exchange market is a bit of a mystery in most states.
Unfortunately, Vermont is one of the three states (along with Idaho and Maryland) which hasn't released any 2019 Open Enrollment data yet, so I don't have any numbers to report on that front. However, they did just post this "Open Letter" which I found interesting. The two things to keep in mind about Vermont are: 1) they include their own subsidies on top of ACA subsidies; and 2) they were among two states (North Dakota is the other one) which upgraded their premium pricing in 2019 from "no load" to full #SilverSwitcharoo status.
You can read about the wonky mechanics of this here, but the bottom line is that Vermont residents who qualify for subsidies have substantially better deals available this year, while unsubsidized enrollees have an important workaround to avoid being stung with extra CSR costs:
Open Enrollment is the annual period when new applicants can use the marketplace to sign up for health and dental plans for the coming year. It is also the time that existing members have the option to change plans – an option that many more members than usual will want to consider.
Much more financial help - Subsidized members will receive over $1,200 more in premium subsidies in 2019 than they received in 2018. This is because the premiums for Blue Cross Blue Shield of Vermont (BCBSVT) and MVP Health Care (MVP) on-exchange silver plans are increasing significantly. Premiums for silver plans drive federal subsidies—so when the premiums for silver plans increase, subsidies also increase. Premium subsidies can be used on any metal level plan, bronze through platinum (see illustration of what the typical member pays in 2018 vs. 2019).
In other words, Vermont has finally jumped onboard the #SilverSwitcharoo Express!
Vermont's situation is unusual compared to most other states for a couple of reasons. First of all, VT is one of only two states (Massachusetts is the other one) which has merged their Individual and Small Group market risk pools into one to help stabilize both markets. This is something I wish every state would do, frankly, although it's probably a lot easier to do in deep blue states (and Vermont having such a small population probably made it easier as well).
20 states went the full #SilverSwitcharoo route (the best option, since it maximizes tax credits for those eligible for them while minimizing the number of unsubsidized enrollees who get hit with the extra CSR load);
16 states went with partial #SilverLoading (the second best option: Subsidized enrollees get bonus assistance, though not as much as in Switch states; more unsubsidized enrollees take the hit, but they aren't hit quite as hard);
6 states went with "Broad Loading", the worst option because everyone gets hit with at least part of the CSR load except for subsidized Silver enrollees;
6 states took a "Mixed" strategy...which is to say, no particular strategy whatsover. The state insurance dept. left it up to each carrier to decide how to handle the CSR issue, and ended up with a hodge podge of the other three
3 states (well, 2 states + DC, anyway) didn't allow CSR costs to be loaded at all. Their carriers have to eat the loss, which makes little sense, but what're ya gonna do?
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.
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.
Vermont wraps up 2018 open enrollment for Vermont Health Connect
News Release — Department of Vermont Health Access Dec. 19, 2017
Vermonters who Didn’t Complete Plan Selection Urged to Call this Week
WATERBURY, VT – State officials reported that nearly 23,000 Vermonters had confirmed a 2018 health plan and qualified for financial help to make the plan more affordable. Total enrollment in qualified health plans, which typically includes 46,000 small business employees and 11,000 individuals who don’t qualify for financial help, is expected to surpass 80,000. While enrollment will be similar to past years, this year’s earlier deadline means fewer members will experience gaps in coverage. In past years, nearly 2,000 members missed out on January coverage.
Vermont has been pretty much on radio silence for the past two years. They issued fairly regular enrollment data reports in 2014 and 2015, but last year there was nary a peep; the only mid-season enrollment report with Vermont data was the official one released by CMS in early January.
Vermont was one of the first states I analyzed back in the late spring; obvoiusly a lot has changed since then, so I updated/revised my analysis of their requested rate hikes for 2018 a couple of weeks ago, with requested average increases of 11.9% if CSR payments are made or 21.6% if they aren't.
Yesterday, Louise Norris gave me a heads up that the Vermont regulators have issued their approved rate increases for the two carriers operating on the individual and small group markets in the tiny state. This makes Vermont the 4th state to announce their approved rates for next year, joining Oregon, Maryland and New York.
As noted in the Virginia and Maryland updates, I've started going through the earlier state rate filings and revising them to include:
Updated/revised carrier rate filings;
Additional market withdrawls and/or expansions;
Corrections to CSR factor impact, etc.
The original versions of each state writeup includes screen shots of the actual filing documents and explainers behind specific requests; I don't have time for that with most of the updates, so I'm bundling several states together. Here's Connecticut, Oregon and Vermont's revisions:
Vermont is the 4th state to post their initial 2018 rate filings. Vermont has a couple of unusual policies re. their healthcare market: First, while they do technically have an off-exchange individual market, those policies are all fully ACA-compliant QHPs and are tracked exactly the same as on-exchange QHPs, meaning this dashboard report from February includes just about all of their individual market enrollees: 28,775 on exchange + 5,662 off-exchange, for a total of 34,437 ACA-compliant enrollees. Vermont didn't allow transitional plans, so aside from an unknown number still enrolled in grandfathered plans, that should represent their entire individual market.
As I've noted before, until today, there was one state which I had no OE4 data for whatsoever: Vermont (which is ironic given their historic support of healthcare reform, including Sen. Bernie Sanders). This blank has been filled in by today's supplemental CMS/ASPE report: 29,021 QHP selections as of 12/24, which is actually quite a bit higher than I expected for the state (my target for VT is only 30,000 total through 1/31).