UPDATE: 1.8 - 2.4 Million more Americans would likely #GetCovered if HealthCare.Gov launched #COVID19 SEP

4/16/20: Important Update at bottom!

With all the anger at CMS Administrator Seema Verma, HHS Secretary Alex Azar and of course Donald Trump himself over CMS's refusal (to date) to open up a COVID-19 specific Special Enrollment Period on the federal ACA exchange (HealthCare.Gov), last week I decided to try and figure out just how many people are enrolling across the 12 state-based exchanges which are offering CV19 SEPs...and just as importantly, how many people would likely take advantage of a CV19-specific SEP on the federal exchange if and when they ever decide to go ahead and launch one.

At the time, I was working with very spotty data from only a handful of state-based exchanges. this was further complicated by the fact that the start dates and deadlines vary from state to state. Finally, a few of the states (Connecticut and Washington State) are requiring those using the CV19 SEP to call the exchange (as opposed to simply using the website as normal) or, in the case of Nevada, they have to either call or turn in a special form attesting that they didn't already enroll earlier in the year, which isn't quite as simple as a SEP completely open to any uninsured resident.

You can see all the underlying data from last week here, but today there's some new and updated numbers available, including from the Big One: Covered California.

California is the largest state in the country (12.0% of the population), and CoveredCA is the largest state-based exchange (13.5% of all ACA exchange enrollments during Open Enrollment this year). All 13 state-based exchanges combined account for 27% of ACA exchange enrollments, which means that California singlehandedly holds 50% of that. CoveredCA releasing their CV19 SEP data is therefore a huge part of extrapolating more accurate data nationally.

With the very rough data I had last week (from CO, CT, MD, MN, NV & WA, which only hold 7.3% of all exchange enrollments combined), I estimated that the 12 states offering CV19 SEPs would likely enroll a total of around 250,000 people if their SEPs lasted 60 days. I further concluded that if HealthCare.Gov were to do so as well (along with Idaho, the only state exchange not offering one), that would likely mean an additional ~10,000 people per day enrolling across those 39 states, or over 600,000 additional Americans getting covered in HC.gov states over a 60-day SEP.

Today, I'm recompiling the data into a cleaner format, including the critical, just-released data from Covered California as well as updated numbers from Nevada. With the additional data, my estimates are down a bit from lasts week, but not by much:

As of this writing, I've confirmed that at least 60,000 people have enrolled in Qualifying Health Plans (QHPs) via 7 of the state-based exchanges (SBEs) offering COVID-19 SEPs so far (I'll add data for the other 5 states, or updated numbers for these 7, as I aqcuire them). It's important to note that these enrollments are only those which utilized the CV19 SEP itself, not the normal Special Enrollment Periods for Qualifying Life Events.

For instance, California reports 58,400 SEP enrollments total, but says this is nearly 3x more than the 20,000 they had during the same time period last year. That means around 38,400 "extra" SEP enrollments during that period. Some of the other SBEs explicitly state in their press releases that their numbers are only for the CV19 SEPs, or they separated them out when I inquired.

This averages out to over 2,900 per day across those 7 states. I've extrapolated this out to estimate over 3,900/day across all 12 states, which should total roughly 237,000 CV19 SEP enrollees over a 60-day period (the average CV19 SEP time window as of this writing is 59 days).

I then extrapolated this out further to find out what the numbers should look like nationally if HC.gov and Your Health Idaho were to launch their own official CV19 SEP, as opposed to the normal QLE SEPs available in every state. I concluded that roughly 13,800 people would enroll on average each day via CV19 SEPs nationally, or around 9,900 per day via the 38 states hosted by HC.gov (+ Idaho) specifically.

Over a 60-day SEP, this would add up to around 593,000 additional Americans enrolling in ACA exchange policies if CMS were to launch a COVID-19 specific SEP open to anyone currently uninsured without requiring documentation of coverage loss/etc.

Of course, some of those 593K likely are enrolling in HC.gov states anyway using normal SEPs...except that as I noted a couple of weeks back, those require documentation of a Qualifying Life Event which can be extremely cumbersome to get ahold of and upload...and even then, they have to be verified by CMS which could take weeks. How many have (or will) go through all those hoops? That's unknown, and CMS isn't talking so far.


It's also important to note that these estimates are mostly based on the 3.3 million people who newly-filed for unemployment in the 3rd week of March only. Look at the date ranges above...the average end date for the data is April 5th. Anyone who lost their job between March 15th - 21st isn't likely to have started scrambling to replace their health insurance immediately, since there are a lot of other issues to deal with as well; I assume most of them didn't get around to visiting CoveredCA, HealthSource RI, etc. until the following week. These numbers probably do include some of the second wave of 6.8 million who filed for unemployment the following week, but hardly any of the third wave of 6.6 million the week after that.

Let's assume this reflects nearly all of the first 3.3 million, plus perhaps 1/3 of the second week. That'd mean around 830,000 enrolling nationally out of roughly ~5.6 million unemployed, or around 15% of the total unemployed.

If so, then that would mean roughly 2.5 million of the first 16.8 million to lose their jobs would likely enroll in an ACA exchange QHP during a COVID-19 SEP if offered nationally...around three times higher than the estimates listed above. And of course that assumes the unemployment roles don't continue to shoot up past 16.8 million, which they likely will.

If all of my assumptions are accurate, that means up to 710,000 Americans could enroll via CV19 SEPs across the 12 state-based exchanges offering them, and an additional 1.8 million would likely do so across the other 38 states hosted by HealthCare.Gov (+ Idaho) if they were to do so as well.

I don't have much data re. the numbers "ramping up" yet, but one key data point: The Nevada exchange reported 1,534 enrolling via CV SEP in the first 21 days, or 73/day on average. Today they confirmed that this is up to 2,139 Nevadans as of Sunday night (27 days). That means an additional 605 have enrolled using the SEP in just 6 more days, or 101/day on average...a 38% daily increase.

UPDATE 4/16: The latest weekly unemployment figures are out for the fourth week of the COVID-19 pandemic lockdown, and the numbers aren't getting any prettier:

More than 5 million Americans filed for unemployment benefits last week, bringing the total in the month since the coronavirus pandemic throttled the U.S. economy to 22 million and effectively erasing a decade worth of job creation.

Initial jobless claims of 5.25 million in the week ended April 11 followed 6.62 million the prior week, according to Labor Department figures Thursday. The median estimate of economists was for 5.5 million, with projections ranging as high as 8 million.

The four-week sum compares with roughly 21.5 million jobs added during the expansion that began in mid-2009.

As I note above, my lowball estimate of 600,000 potential HC.gov ACA enrollments is based on the first 5.6 million unemployed (around 11%), while the 1.8 million estimate was based on 16.8 million unemployed in the first 3 weeks of the shutdown. At 22 million, I have to upgrade my estimate to 2.35 million:

  • 900,000 via the 12 state-based exchanges which already have COVID-19 SEPs
  • 2.35 million via HC.gov states if they were to launch a 60-day "open" COVID-19 SEP
  • 3.25 million nationally