An Open Letter to Every ACA Exchange

UPDATE: I've confirmed that Maryland and Massachusetts do both plan on continuing to issue at least monthly reports during the off season (I'd prefer weekly but I'll take what I can get).

As of today (February 27th), the 2015 Open Enrollment Period has ended in 47 states (KY, MD, NY & WA states are still allowing "In Line by Midnight" extensions through tomorrow night or all the way out until April, and CO, CT, DC & HI have taken a sort of "case by case basis" approach with no specific hard deadline).

After that comes #ACATaxTime: 46 states have officially announced some sort of special Tax Season enrollment period, officially limited to people who had to pay a finanical penalty for not having required healthcare coverage in 2014, missed getting covered for 2015 by the official deadline and "didn't know about the penalty" until now. Officially, the number of people who could potentially qualify for #ACATaxTime is somewhere between 0 - 6 million. Of course, that last requirement is awfully difficult to prove one way or the other, and I suspect that neither the HHS Dept, ACA exchange nor IRS are likely to push this point too closely. Anyway, the tax season Special Enrollment Period (SEP) is scheduled to run from March 15 - April 30 in most states, but starts earlier or ends later in a handful. 5 states haven't made any such announcement yet; I'm expecting at least some of them to do so soon.

After that, barring any further SEPs, health insurance enrollment will be officially closed to most people...with some exceptions:

  • Qualifying Life Events: If you get married, get divorced, give birth, adopt a child, lose a job with ESI, move to a different state, gained citizenship/legal residency or a number of other major life changes, you can still enroll. Don't take this lightly: In 2014, roughly 9,000 people were still enrolling every day even during the off-season via qualifying life events (a similar number of enrollees were also dropping their coverage for similar reasons as well, of course).
  • Native Americans can enroll any time throughout the year.

In addition, there's also no deadline for enrolling in Medicaid, CHIP or SHOP (the Small Business Marketplace).

The point is, of course, that just because Open enrollment is over, there's still likely to be a lot more people enrolling in policies throughout the rest of the year. Possibly as many as a million people via the Tax Season period, and up to 270,000 every month beyond that...potentially 2 1/2 million people from now until October (when 2016 open enrollment starts up again). That's potentially more people selecting plans than enrolled in the entire first half of 2014's open enrollment period (even if a similar number are also dropping out as well).

Last year, after the dust settled on the open enrollment period, the HHS Dept.--which had already been taking a lot of heat for lack of transparancy with the enrollment data during the 2014 open enrollment period, issuing updates only monthly and being very cagey about the data in between--announced that they were going to stop issuing even the monthly reports during the off season.

Needless to say, many healthcare reporters and wonks, including myself, were furious about this announcement. A few of the state exchanges, thankfully, continued to release regular enrollment updates (especially Minnesota and Oregon, if you can believe it, along with occasional reports from Maryland and Colorado), but otherwise it was radio silence from and most of the other exchanges. My 9K/day estimate proved to be about right, but it would've been much easier if they'd just released the data regularly instead of my having to extrapolate from a tiny percentage.

Anyway, cut to November 2014: New enrollment period, vastly improved exchange websites, a new HHS Secretary, a new "CEO" for a pleasant surprise: started releasing weekly enrollment snapshots. Then, on top of that, they started breaking those weekly numbers out by state! In addition, many of the state exchanges, which had been scattershot about their own enrollment data, became more transparent as well: Massachusetts released daily overviews (and weekly detailed reports); Rhode Island and Vermont went weekly, and so forth. Eventually, eventually actually said to heck with it and started breaking it down by municipal area (which is actually more detail than even I needed, but a nice touch).

Obviously I was thrilled about these development.

And then...this happened:

Each week during Open Enrollment 2015, weekly snapshots were released to provide a more detailed look at the millions of consumers who visited, shopped for coverage, selected plans or were automatically re-enrolled through the platform; which includes the Federally Facilitated Marketplaces, State Partnership Marketplaces and supported State-Based Marketplaces.

The Open Enrollment snapshots for the Federally Facilitated Marketplace provided point-in-time estimates for weekly data. These were preliminary numbers and fluctuated based on consumers changing or canceling plans or having a change in status such as new job or marriage. Open Enrollment ended on February 15 but consumers who waited in line at the call center or who experienced technical issues were able to sign-up for coverage until February 22 through a special enrollment period. This is the final Open Enrollment 2015 snapshot and includes data through February 22 to capture those consumers who signed up for affordable coverage during the special enrollment period.

...HHS will produce a more detailed report that looks at plan selections across the Federally Facilitated Marketplace and State-Based Marketplaces in March. In addition, the weekly snapshot only looks at plan selections and automatic re-enrollment. It does not detail the number of consumers who paid their premiums to effectuate their enrollment.

Notice the past-tense, "final" wording scattered throughout? My fear from this wording is that in spite of their openness/transparancy during the 2015 Open Enrollment Period, they've decided to once again pull up stakes and shut down the data reporting again during the off season. Just when I thought they finally had it, they may not have after all. The state exchanges may or may not be planning on pulling the plug on reports as well (I've gotten mixed responses from a couple so far).

Therefore, here's my questions for as well as the 14 state-based exchanges:

  1. For those of you who are offering a "Tax Season" SEP, do you plan on releasing enrollment reports throughout that period?
  2. For all exchanges: Do you plan on releasing enrollment reports throughout the "off season" (either now - October or May - October, depending on your Tax Season SEP policy)?
  3. If so, how frequently? (Daily? Weekly? Monthly?)
  4. If so, how much detail will you be providing? (QHP selections only? Paid/effectuated enrollments? Number of enrollees who drop coverage/are dropped for non-payment??)
  5. How about non-QHP data (Medicaid/CHIP? SHOP?)
  6. Will you throw in any additional demographic data (Metal Levels, APTC data, CSR data, county-level data, etc), that's fine with me as well?
  7. Finally, if you're not planning on providing off-season enrollment reports, why not?

As I've said many times, I'm not expecting a massive 40-page report like the monthly ones put out by ASPE during the open enrollment periods. I'm just talking about weekly (or monthly, I suppose) "snapshot reports" along the lines of the ones you've been issuing recently. The more detail the better, of course.

I've already asked these questions of a few exchanges individually, so my apologies to the ones who have already responded, but I wanted to get this all out at once.

Thanks in advance for your responses,

--Charles Gaba