Oregon: Paid QHPs only up 10. End of COBRA extension to blame??

Hat Tip To: 

Hmmm...OK, first it was Hawaii with the QHP total actually going down from 6/28 through 7/05. Then Minnesota reported a huge drop-off in their off-season enrollment rate, from about 52 per day from April through the end of June to just 2 per day for the first 13 days of July.

Now we have Oregon's latest update. While the total QHP figure has grown by 1,092 over the past week, the paid QHP number has only gone up by...10. That's right: Just 10 in the past week, or just over 1 person per day...down from over 300 per day in the off season until now.

(As an aside, new Medicaid enrollments are also slowing down, with just another 290 people being added to the program). 

July 14, 2014

Medical enrollments through Cover Oregon: 321,290
Total private medical insurance enrollments through Cover Oregon: 93,698
Oregon Health Plan enrollments through Cover Oregon: 227,592

Net enrollments
Net private medical: 82,637

Net numbers are enrollments remaining in the system on this date after cancellations and terminations.

So...what's going on? Obviously 3 states in a row going from impressive off-season numbers to single digits per day, all within the same 2 day period is not a coincidence or an anomaly...and I think I've figured out why:

There has also been some confusion as to how having COBRA coverage affects an individual’s coverage options after open enrollment.  See CMS May 2, 2014, Guidance Material.  During open enrollment, individuals with COBRA coverage may voluntarily drop their coverage and enroll in Marketplace coverage, regardless of whether COBRA coverage has expired.  After the open enrollment period, if an individual’s COBRA coverage expires, they would qualify for a special enrollment period and would have 60 days to purchase Marketplace coverage.  See 45 CFR 155.420(d)(1).  For 2014, individuals eligible for COBRA coverage and COBRA beneficiaries have until July 1, 2014, to enroll in Marketplace coverage.  After that, if an individual cancels COBRA coverage outside of open enrollment, they would not qualify for a special enrollment period, unless some other qualifying event occurs.

Yup. Hundreds of thousands of people nationally are on COBRA insurance coverage temporarily at any given time, and in 49 out of 50 states, that particular special extension period ended on July 1st.

The exception to this is California, which bumped their own COBRA enrollment period (which impacts up to 300,000 people) out by another 2 weeks...through today:

California's health exchange said an estimated 300,000 people in the state with COBRA insurance coverage can switch to an Obamacare policy through July 15.

The Covered California exchange announced the special two-month enrollment period, starting Thursday, to address confusion about the sign-up rules.

...The state said its move mirrors a ruling this month from the Obama administration that allows COBRA enrollees to buy health plans through a separate federal exchange until July 1.

Now, I've said all along that I do expect the May/June 9,500/day QHP enrollment rate to drop off somewhat as we move into late summer and into the fall, partly because the COBRA extension period is being cut off in July. I just didn't think it would drop off THAT much.

However, if I'm correct about this, it looks like the COBRA enrollments may have been making up a good 90% of the off-season additions...and if that's the case, then I've seriously overestimated the number of additional QHPs which will be enrolled in between July and November.

The numbers should be propped up a bit through today (7/15) because of California's 2-week extra extension, but after that, if I'm correctthe numbers will likely crater to perhaps 1-2% of the Open Enrollment rate instead of the 20-25% that they've been at so far.

If that happens, then the daily rate nationally may drop from around 9-10K/day down to under 1,000/day...or only a couple hundred thousand on top of the 8.7 million or so I have estimated as of early July. That would top things out at no more than 9 million (total) as of 11/15, or 8.1 million paid QHPs.

I'll keep a close eye on this and will write a more definitive post soon...