Here's one more reason why some people are already dropping 2018 policies...

Fire up the wayback machine, Sherman, and set your course for late 2014:

Default Re-Enrollment: Under current rules, consumers who do not take action during the open enrollment window are re-enrolled in the same plan they were in the previous year, even if that plan experienced significant premium increases. We are considering alternative options for re-enrollment, under which consumers who take no action might be defaulted into a lower cost plan rather than their current plan. We are considering allowing states to pursue these sorts of re-enrollment alternatives for coverage in 2016. The FFM is exploring such an approach for coverage in 2017.

Hoo, boy. I completely understand why they're thinking about doing this; a lot of healthcare wonks are already wringing their hands (myself included) over the possibility that millions of people who "auto-renew" 3 days from now without bothering to visit their exchange website and shop around will wake up to sticker shock when they receive their first 2015 premium bill in the mail. Defaulting them into a lower-cost policy makes sense on paper, since it's to their own benefit and avoids the enrollee being outraged over a price spike.

However, it also presents a different problem: Big Gub'mint Mucking Around With My Healthcare®, etc, etc. Basically, this plays into every cliche that right-wingers have about "Government Takeover of Healthcare" and "The Nanny State treating grown adults like children" and so forth. That's how you get essays like this one from the CATO Institute:

Under Proposed Rules, Government Could Choose Insurance Plans for Millions of People

The administration is considering a rule change that would allow the government to automatically change some people’s exchange plans to a cheaper alternative.

...For people that chose this option, the government would be effectively choosing their insurance plan, a far cry from the “if you like your plan you can keep it” pledge.

The thing is, they kind of have a point...look at how much hollering the Obama administration heard over the "OMG!! GAZILLIONS OF POLICIES CANCELLED!!" issue last year, even though the insurance companies had over 3 years to get their policies up to snuff (and already have a long history of dropping them without notice anyway).

Plus, this wouldn't even really solve the "rude awakening" problem anyway. Instead of having "sticker shock" they'd have "provider change shock" or whatever. The ones who are responsible enough to understand why they were switched are likely to also have been wise enough to actually actively decide whether/how to renew in the first place anyway.

At the time, CMS was mulling over the idea of auto-switching people to a different, lower-priced policy even if their current one was still available. Thankfully, they scrapped this idea and instead only switch people to a different plan if their current one is no longer on the market.

However, the rest of my response still holds some weight: People really, really don't like their current choice of plan being messed with against their express wishes, so if you're gonna do so you should proceed with caution.

That being the case, here's how HealthCare.Gov handles "mapping" auto-renewals into different policies when the one they're currently enrolled in is no longer available, as explained by the amazing Louise Norris:

...When plan designs are phased out and replaced, carriers “map” insureds to different plans that are the “most similar” to what they currently have. It’s a better option than having policyholders lose their coverage altogether if they don’t return to their exchange to actively research and select a new plan.

Unfortunately, even if you’re mapped to the “most similar” plan, it could mean that the premium, provider network, and design of your mapped policy could all be different from what’s in your existing plan.

In September 2014, HHS clarified that auto-renewal would be the default provision to avoid gaps in coverage for exchange enrollees who don’t return to actively select a new plan for the coming year during open enrollment....In most cases, the expectation is that the same plan will be available in the coming year, and enrollees who don’t return to the exchange to select a plan during open enrollment are simply auto-renewed in their current plan.

So auto-renewal for 2018 is available for most current enrollees. But that does not mean they’ll all be renewed onto the same plan they had in 2017, or that the provider network will still be the same. If a current plan will no longer be available, the carrier can “map” insureds to a new plan that they deem to be “most similar” to the current plan. And if the carrier is exiting the exchange, the enrollee can be automatically re-enrolled in the plan that the exchange deems the closest match, assuming that the enrollees don’t return to the exchange to pick their own new plans.

...For cases where an existing plan won’t be available in the coming year, HHS implemented a hierarchy in 2015 for determining what plan would be considered “most similar” to an enrollee’s current plan. HHS noted that the insurance carriers (as opposed to state regulators or the exchanges) are uniquely qualified to determine which plan is most similar to a plan that will no longer be available.

Let's suppose you're currently enrolled in a particular Gold PPO through Blue Cross. If that exact same plan is no longer available, you'd be mapped to an extremely similar Gold Blue Cross PPO. If none are available, then you'd be mapped to, say, a Silver Blue Cross PPO. If no PPOs are available, you'd be mapped to a Gold Blue Cross HMO; if that's not available, you might be moved to a Silver Blue Cross HMO. I may have the hierarchy reversed regarding metal level and network size, but you get the idea: You're kept as close to your current plan as possible within the same carrier.

HOWEVER...what happens if your carrier leaves the ACA exchange (and in most cases the off-exchange individual market) altogether? That's where things get a big ugly:

For 2017, and again for 2018, we’re seeing a not-insignificant number of carriers leaving the exchanges altogether. Obviously, all of the impacted enrollees have the option to return to the exchange during open enrollment to pick a new plan. But not everyone in that situation will do so. How does auto-renewal work in that situation?

...But for 2017, new rules were implemented, and they’re still in use for 2018. In the Benefit and Payment Parameters for 2017, HHS noted that

“whenever feasible, the Exchange should, and the FFE will attempt to, re-enroll enrollees in silver metal-level QHPs no longer available through the Exchange into the silver metal-level QHP offered by another issuer through the Exchanges of the same product network type with the lowest premium.

If the QHPs that have become unavailable are in metal levels other than silver, then whenever feasible, the Exchange should and the FFE will seek to re-enroll the affected enrollees in the QHP available on the Exchange of the same metal level of the same product network type with the lowest premium.

Exchanges should, and the FFEs will endeavor to, implement such a re-enrollment process for enrollees of QHPs whose issuers are discontinuing their coverage, for as many groups as is feasible given the short timelines and complex operations that could be required in these scenarios.”

Essentially, the exchange will — if possible — assign people to a new plan from a different carrier in the exchange, if the enrollee’s current carrier will no longer be offering plans in the exchange after the end of the year. Note that they use the words “the FFE will attempt to…” and “the FFE will endeavor to…”

I think you begin to see the problem here. On the one hand, as I noted back in 2014, I completely understand why they're doing this: CMS is doing everything they can to make sure that people don't lose coverage in spite of themselves. That's a noble and positive goal.

However...there are some people who simply don't pay attention to the various notices, reminders and explainers which are emailed, texted or even physically mailed to them to explain what will happen if they don't take any action. And guess what the response from someone with that mindset is when they suddenly receive a premium invoice from some insurance company they've never been an enrollee of before?

Sure enough, an insurance broker friend of mine confirms that the effectuation rates on people who are "cross-enrolled" into one of their policies from a different carrier stinks; as they put it, "they receive an invoice from an insurance company they don't think they're doing business with and just throw it in the garbage". They can't actually send out those invoices until after 12/15, so most people only received them within the past week or so...and lo and behold, that's led to a number of angry/confused phone calls from people dropping their plans. This almost certainly accounts for a decent chunk of the 12/15 - 12/23 drop in HC.gov enrollment just announced earlier today, although it's hard to separate out from the other factors I discussed.

Anyway, this is exactly what I was concerned about a few years back. It sounds to me like mapping people to different policies from the same carrier goes over alright, but switching them to a completely different company is a bridge too far for many. Perhaps CMS should rethink this policy going into 2019 (assuming Trump's CMS head gives it any thought whatsoever, that is).

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