A Thanksgiving apology and thank you to the folks at CCIIO


(h/t to former CCIIO Director Gary Cohen for the reminder)

You've probably never heard of the Center for Consumer Information & Insurance Oversight (CCIIO)...

The Centers for Medicare & Medicaid Services’ Center for Consumer Information and Insurance Oversight (CCIIO), part of the Department of Health & Human Services (DHHS), provides national leadership in setting and enforcing standards for health insurance that promote fair and reasonable practices to ensure that affordable, quality health coverage is available to all Americans. The center also provides consumers with comprehensive information on coverage options currently available so they may make informed choices on the best health insurance for their family.

...but among other things, they're the folks who actually implement the ACA, including, among other things, HealthCare.Gov (I'm not sure if it's the same team that operates HC.gov or not...probably a lot of overlap between the two?).

Consumer Information and Insurance Oversight

Ensuring the Affordable Care Act Serves the American People

The Center for Consumer Information and Insurance Oversight (CCIIO) is charged with helping implement many reforms of the Affordable Care Act, the historic health reform bill that was signed into law March 23, 2010. CCIIO oversees the implementation of the provisions related to private health insurance. In particular, CCIIO is working with states to establish new Health Insurance Marketplaces.

CCIIO works closely with state regulators, consumers, and other stakeholders to ensure the Affordable Care Act best serves the American people.

I'm embarrassed to admit that in four years of blogging about the ACA in general and the exchanges in particular, I don't think I've ever made a direct reference to CCIIO before today (they've been referenced in a handful of quotes from bulletins or other articles that I've cited, but I've never talked about them myself).

Over the summer, I speculated that due to the Trump Administration's open hostility towards the ACA and blatant, over-the-top attempts at sabotaging the implementation and administration of the law, I "wouldn't be surprised" if the federal exchange (HealthCare.Gov) suffered from massive problems this fall. As I said in July:

This brings me to the main point of this entry: This is likely just the beginning. I'm not going to say that any or all of the following will happen--it's possible that Trump/Price/Verma will show some level of restraint--but I wouldn't be at all surprised to see any or all of these happen during this fall's Open Enrollment Period (which runs from Nov. 1st - Dec. 15th, by the way):

  • Minimal or non-existent advertising/outreach/promotional efforts
  • Understaffing of call centers/support staff, leading to absurdly long hold times
  • Deliberately underthrottled server bandwidth, slowing HC.gov down or even taking it offline, especially during peak hours
  • "Accidentally" misentered enrollment instructions or policy specifications
  • Confusing or missing confirmation/status notification messages either on the site, via email or both
  • Incorrect APTC/CSR subsidy formulas giving incorrect tax credit/financial assistance details to enrollees
  • Burying/completely removing the "Window Shopping" tool on the site

...Again, I don't think they would take it quite that far; my guess is that they'll keep the site running mostly as it's supposed to, not doing anything too blatantly obvious...just enough to deliberately increase the general distrust and unease people have over Trump and, more to the point, of "government run healthcare" in general.

Instead, while Donald Trump, Tom Price (until he was canned), Seema Verma and other top-level HHS/CMS officials absolutely have been undermining, shortchanging, sabotaging and otherwise messing with Open Enrollment as much as they can...the actual logistical and technical launch and operation of HC.gov has actually been remarkable in how unremarkable it's been.

In fact, I only know of three technical glitches so far...all of which have been nonissues for the most part:

  • In New Mexico, due to Trump's last-minute CSR cut-off, CHRISTUS health plans had to scramble to reprice their policies and ended up being kicked off HC.gov for the first two weeks of Open Enrollment. This triggered a bit of a mess with the tax credit formula for those enrolling with the other three carriers. This has since been resolved, however, and again, the confusion was caused by Donald Trump, not the folks actually running the exchange.

Basically, there's a surreal dynamic which has developed between the Trump appointees who did/are doing everything to undermine/sabotage OE and the career folks who are doing everything they can to make it work properly...and for the most part have been successful to date.

I therefore issue an apology and a thank you to CCIIO employees for proving me wrong and everything you've done and continue to do to make OE5 a success under what I'm sure are extremely difficult conditions.

Let's keep it up and see if we can make Trump & Co. eat crow instead of turkey this Thanksgiving!

UPDATE: D'oh!! I almost forgot to also issue a big thank you/shout-out to the folks running the 12 state-based exchanges as well! Things aren't quite as insane for them as the HC.gov staff, but it's still definitely been a trying period: