Wisconsin: 36% rate hikes approved; nearly half due specifically to CSR cut-off

Back in August, I posted a rough analysis of the requested rate increase situation for Wisconsin's individual market carriers. However, I cautioned at the time that I was missing the enrollment market share numbers for four of the carriers (Aspirus, Compcare, Wisconsin Physician Service and WPS), and therefore had to guess at how the rate hikes for those carriers would impact the statewide average. I estimated the numbers assuming CSR payments are made at 21.7%, and from that assumed the impact of CSR reimbursements not being made would be around 7.8 additional points being tacked onto the average.

A couple of weeks ago, the state insurance commissioner announced the approved rate increases. The good news is that I overestimated on the "CSRs paid" front. The bad news is that I underestimated on the "CSRs not paid" front: It's actually 20% and 36% respectively:

Wisconsin insurance officials say Wisconsin residents buying health coverage on the Affordable Care Act exchange will see an average premium increase of 36 percent. The great majority, 90 percent, will get federal subsidies to defray that cost.

However, Wisconsin residents buying health coverage in the small group market will see single-digit increases in health premiums next year.

So where do I get the 20% figure from?

Although the average increase for marketplace plans in Wisconsin is 36 percent, some areas of the state will see rates for the second lowest cost plan, the silver plan, double.

According to the OIC, the premium increase for silver plans will be 40 percent, 21 percent for bronze plans, and 19 percent for gold plans.

I'm assuming the "double" wording is misrepresenting the silver increase; it's not "doubling"; the rate increase is double that of other plans (40% vs. 20%), unless there really is a county or two in which the silver plans are going up 100%.

Update: Strike that; as explained by commenter 'Robin' below, yes, a few counties in WI are indeed seeing the unsubsidized Silver benchmark plan double...and Robin confirms that at least two WI carriers are indeed going the full Silver Switcharoo route...which would be consistent with benchmark plans increasing dramatically.

In any event, it's pretty clear that silver plans would only be going up about 20% without the CSR load, which means that Wisconsin is definitely "Silver Loading" (and my possibly even be doing the "Silver Switcharoo", although that's harder to tell; I've put in a requeste with the WI DOI to clarify.

As for what happens if the carriers do end up getting reimbursed for the lost CSR payments, Wisconsin, like Louisiana, is being pretty frank about it:

Wisconsin Deputy Insurance Commissioner J.P. Wieske said Friday that Trump's announcement does not change the 36 percent increase projection the state made. However, he said if the subsidies remain, it could mean that policy holders would see a refund or lower costs in 2019.

Of course, the Deputy Insurance Commissioner fails to mention that the reason why policy holders would see a refund in 2019 is because of the ACA's 80/20 MLR rule.