Vermont

2018 MIDTERM ELECTION

Time: D H M S

Last night I made a big fuss about New Jersey Governor Phil Murphy signing a restoration of the ACA's individual mandate penalty into law.

It turns out that the Governor of Vermont also signed the ACA mandate restoration bill I wrote about back in March into law a few days ago as well...but it's not as noteworthy, for several reasons. As Louise Norris reports over at healthinsurance.org:

Vermont governor signs legislation to implement an individual mandate starting in 2020; working group will sort out enforcement details

I had actually already written about Vermont doing this back in March, but seeing how it was one of only 2 states (+DC) which didn't allow Cost Sharing Reduction (CSR) costs to be loaded onto premiums at all this year, I figured I should mention it here as well. Once again:

  • 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.

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:

A huge shout-out to Ken Kelly for calling my attention to this press release which was apparently sent out way back on December 19th???

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.

Eureka! I've finally acquired fairly up-to-date Open Enrollment data for the last blank state on my list: Vermont. The exchange representative kept it simple for me:

Vermont’s net plan selections as of December 2, 2017:

  • 25,559 renewing individuals
  • 1,335 new individuals (including those previously, but not currently, enrolled)
  • 26,892 total individuals

Last year Vermont ended OE4 with 30,682 QHP selections total, so they were up to around 88% of that total as of Saturday with 13 days left to go.

...well, not a whole lot, to be perfectly frank.

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.

I was, therefore, pretty happy to see a link to their "2018 Open Enrollment Update" posted earlier this afternoon.

Unfortunately...

Open Enrollment Countdown: Just 15 Days Left to Sign up for 2018 Health Coverage

Customer Support Center to Open Next Two Saturdays (9am-1pm)

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.

Along with today's HHS report which confirms more than 11.5 million 2017 QHP selections as of Christmas Eve, CMS has released an additional report which breaks the numbers out by state...and unlike HC.gov's "snapshot" reports (which only cover 39 states), the CMS/ASPE report also confirms the enrollment numbers for all 50 states (PDF).

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).

Last month I noted (well, after Louise Norris called my attention to it) that after 2 years of restricting all individual market enrollments to their still-buggy ACA exchange, the state of Vermont actually reversed this policy for 2016 by allowing individuals to enroll in ACA-compliant policies directly through the carriers after all.

This actually goes against the recommendations I just wrote about yesterday, leaving the District of Columbia as the only other exchange to require all indy plans to run through it), but given how many technical problems Vermont seems to still be having with their platform, I can understand them allowing direct enrollment for the time being. I stand by my recommendation that every state should eventually move everything onto the exchange in the future, however.

I noted back in February that Vermont Health Connect, VT's ACA exchange, has remained essentially silent since last fall, issuing only 2 press releases since Open Enrollment started last November (one of which was about a new plan comparison tool, the other of which was about some sort of Medicaid-related dealine). In other words, they haven't publicized their 2016 enrollment numbers whatsoever...the only reason I have data for VT at all is thanks to the official ASPE reports from the HHS Dept. This is a stunning 180º turnaround from 2015, when they were issuing detailed reports on a regular basis.

Like most states, Vermont does have an account with the SERFF database system for insurance rate filings. Until today, I assumed that they just hadn't posted the 2017 filings yet, since there's only one unrelated listing there at the moment.

However, thanks to an anonymous tipster for reminding me that Vermont also has their own, in-house rate review website...and the state is pretty easy to run the math on due to the fact that....

  • There's only 2 carriers in the state even offering individual or small group policies at all,
  • Under state law, all individual/small group policies have to be sold on the ACA exchange anyway, and
  • Unlike most states, Vermont is apparently requiring that the risk pools for individual & small group policies be merged, so there's only 1 set of rate changes his year (last year they did have slightly different average rate hikes for the two markets).

Anyway, here's the deal:

As I noted last week, Your Health Idaho has released their final official OE3 number. I had previously noted that there were only 8 states in which the exchanges appeared to have performed worse on private policy enrollment in 2016 than they did in 2015, and that most of those had special circumstances:

Pages