Checking in on OFF-exchange QHP Enrollments... (UPDATED)

Hat Tip To: 
Andrew Sprung, Ken Kelly

In my latest exclusive, I take a look at the off-exchange policy enrollment situation...and just like last year, I think a whole lot of people are going to be shocked when they realize just how many people are signing up for ACA-compliant Qualified Health Plans directly through their carrier.

In addition to this writeup, I'll be revisiting the off-exchange issue soon; I've already contacted 49 state insurance commissioner's offices (Vermont & DC don't have off-exchange enrollments anymore) to see how many are tracking those numbers on a more than annual basis.

Of course, this might have proven to be an exercise in futility. Aside from Oregon (and Washington State, though I have to confirm that for this year), the following should give you an idea of how tall an order this is:

  • Arizona: "Mr. Gaba, ADOI does not have current enrollee data for [off] exchange policies."
  • Connecticut: "We do not have a breakdown of how many policies were sold off exchange for 2015. That’s something the carriers would have."
  • Florida: "Thank you for contacting the Office. The latest information we have available containing aggregated off-exchange enrollment data can be found on Slide #4 from an Office presentation made to the Florida Health Insurance Advisory Board (FHIAB) this past August..."
  • Georgia: "In 2014 there was a data call and information was gathered about the Off-Exchange plans in our state.  However, there has not been a data call this year so we do not have 2015 information."
  • Hawaii: "We do not track that information--only the insurers know that."
  • Idaho: "The DOI does not have this information."
  • Illinois: "The Department hasn’t conducted any survey to request these numbers to date.  We may conduct a survey later in the year but we don’t have the information available today."
  • Kansas: "Health insurers in Kansas are not required to report that information to us at this time. You will need to ask the plans for the information. In the past, they have not been willing to release that information."
  • Kentucky: "Off-exchange enrollment figures are not available at this time."
  • Louisiana: "The latest numbers we have are the numbers current through April 30, 2014On March 1, all insurers will report the number of covered lives in all markets through 12/31/14."
  • Maine: "Sorry,  the Maine Bureau of Insurance will not have enrollment data until mid-April when rate information is filed.  If you require the data earlier we would suggest that you survey each insurance company independently."
  • Massachusetts: Nope.
  • Michigan: "DIFS does not have data on off-exchange enrollments."
  • Minnesota: Nope.
  • Nebraska: "Unfortunately, we do not have that information."
  • Nevada: "The Nevada Division of Insurance does not require carriers to report enrollment data during open enrollment. Therefore we do not know what off exchange enrollment looks like for plan year 2015."
  • North Dakota: "The North Dakota Insurance Department does not track these types of numbers.  You would have to reach out to the various carriers."
  • South Carolina: "We don't have sufficient data to answer the first question."
  • South Dakota: "This information is not available from the SD Division of Insurance. It will need to be obtained from the individual carriers or federal government."
  • Texas: "Thank you for your inquiry to the Texas Department of Insurance.  The department does not collect this data to this level; however you may find data related to this by clicking on one of the following links..."
  • Virginia: "Insurance carriers are not required to report to the Virginia  Bureau of Insurance the number of ACA-compliant individual or small group polices sold for the current calendar year."
  • West Virginia: "Please be advised that our agency has no documents responsive to your request."
  • Wisconsin: "Thank you for contacting the Office of the Commissioner of Insurance for the State of Wisconsin regarding your insurance question.  At this time, this Office is not tracking the information you are requesting."

UPDATE: Hallelujah! Washington State came through after all:

Per your request during our phone conversation yesterday, I have some enrollment numbers as of Nov. 30, 2014:

  • Inside the WA Exchange: 135,972 enrollees
  • Outside the Exchange: 158,671 enrollees
  • Total enrollment: 294,643

You are correct that the health plans approved for sale in Washington for 2015 comply with the ACA.

Now, it should be noted that the 159K off-exchange figure above is as of the end of November, not for 2015, just like the 136K exchange-based figure above it. That does not mean that 158,671 people have already enrolled in off-exchange QHPs for this year.

However, it does add strong further evidence to my post over at that the off-exchange numbers will likely be similar to--or even higher than--the exchange enrollments when the dust settles. 159K / 295K = about 54% of the total in Washington State's case, and will likely see a similar ratio this year, I would imagine.

UPDATE x2: Given the dearth of hard data, and given that no one is really paying any attention to the off-exchange QHPs anyway, I've decided to use estimates for this year based on the same ratios I have from last year in the spreadsheet, at least until I receive hard numbers for 2015. I'm distinguishing these estimates by italicizing the numbers.

So, in Washington State (which was 55% off-exchange last spring and was still 54% at the end of November), I'm multiplying the exchange-based number by 1.16x, or 124,202 for teh moment.

In Florida, as of last June, the ratio was skewed the other way; here's the slide which is referred to in the Florida bullet point above. As you can see, the QHP ratio was 7.35 to 1 in favor of exchange-based another 460K non-compliant policies which aren't relevant for my purposes. In this case, I'm using 13.6% of the exchange-based total for the off-exchange number (yes, I'm sure the ratio has shifted considerably for this year but it's all I have to go on for now).

Using this admittedly questionable formula, I come up with around 360,000 "quasi-confirmed" off-exchange enrollments from those 3 states: 62,678 confirmed in Oregon, 172,855 in Florida and 124,202 in Washington State. I'm already probably way off base here with just the FL & WA numbers, so I'm not going to even try to get into states which haven't provided any off-exchange numbers, and I'm not including this on The Graph or anything, but at least it's a start...

UPDATE x3: OK, I've also confirmed as of May 1st, 2014Nevada had 19,433 exchange-based QHP enrollees vs. a whopping 69,331 OFF-exchange QHP enrollees (not including grandfathered plans, and NV did not allow transitional/grandmothered policies).

So...that's like a 3.5:1 ratio of off-exchange to on-exchange QHPs, the highest I've seen so far.