How many more will enroll via the #COVID19 Enrollment Period? Health Sherpa provides some insight.

Disclosure: Health Sherpa is a paid sponsor of this site.

Back in January, before the ongoing COVID Enrollment Period was officially announced, I ran some back-of-the-envelope math to try and project just how many additional ACA exchange enrollees might sign up nationally due to the addition of a "no questions asked" Special Enrollment Period (SEP) being formally launched across every state, as opposed to the patchwork of COVID SEPs we saw across a dozen states last spring/summer.

I extrapolated those numbers out nationally and estimated that total on-exchange enrollment might increase by perhaps 400,000 more people thanks to a 60-day COVID SEP...that is, 400K more than the "normal" number who typically enroll during that same time period for traditional SEP reasons (losing employer coverage, turning 26, getting married/divorced, moving, giving birth/adopting, etc).

When the actual announcement was made, however, there were a few factors which I hadn't taken into account when I made that projection:

  • First, the official federal COVID SEP is 90 days, not 60 (which surprised me).
  • Second, the pending American Rescue Plan, which includes a long-awaited beefing up & expansion of ACA subsidies, is set to make that subsidy upgrade retroactive to the beginning of 2021 (which also surprised me, though I suppose it shouldn't have).

Connecticut and Idaho are limiting their COVID SEPs to just 30 days, but otherwise every state is going along with the full 3-month time period. Massachusetts is actually tacking on an extra week, and DC doesn't even have a specific deadline--it's simply "until the end of the pandemic".

Both of the bullets above suggest that my 400K figure may be significantly underestimating the potential enrollment increase. A straight-line extrapolation of the first one would mean ~600K additional enrollees, although extra time doesn't mean a corresponding linear increase in enrollment.

The second change could also mean a significant bump as well; the CBO analysis of the House Ways & Means Committee American Rescue Plan bill suggests that an additional 1.7 million people will enroll on-exchange next year. Based on their estimates of additional subsidy amounts in 2021 & 2022, it looks like they figure perhaps 330,000 more might enroll for 2021, although that's a lot trickier to calculate. However, the #AmRescuePlan hasn't even been passed through the House yet, much less signed into law or implemented, so let's set that aside for the moment.

OK, so not accounting for the likely #KillTheCliff / #UpTheSubs upgrade, we're likely looking at somewhere between 400K - 600K additional enrollees nationally between 2/15 - 5/15 on top of the perhaps ~7,500/day or so who historically enroll via SEPs nationally during the off-season under normal conditions.

Earlier this afternoon, George Kalogeropoulos of Health Sherpa--one of the most popular Enhanced Direct Enrollment web partners which has been authorized by CMS to sell on-exchange ACA policies-- posted an interesting tweet:

Excited to announce that in the first week of the new Marketplace SEP, over 40,000 people enrolled through @healthsherpas - more than triple the volume in a typical SEP week. Particularly happy to share that the median net premium so far is $43.67. #GetCovered

— George Kalogeropoulos (@GeorgeK_HS) February 23, 2021

If Health Sherpa was a minor player or if they only operated in a few states, this might not be terribly useful...but Sherpa actually enrolled over 16% of ALL on-exchange enrollees nationally during the official 2021 Open Enrollment Period, and I believe they operate in every state, so this should be pretty good for extrapolating some national data off of.

Again, there's no way of knowing whether Sherpa's COVID SEP Week One experience is representative nationally, but if it is, and if they're still enrolling a similar portion of all COVID SEP enrollments nationally, that suggests perhaps 250,000 people selecting Qualified Health Plans (QHPs) across all 50 states & DC in the first week. Again, you'd normally expect around 53,000 to do so in that period; "more than 3x" that would be around 160K.

This suggests somewhere between 160K - 250K have enrolled nationally in the first week (107K - 167K more than you'd normally see).

Note: I have no idea whether CMS will issue "Weekly Snapshot Reports" during the COVID SEP the way they do during Open Enrollment, but if they do, enrollment via HC.gov should be roughly 72% of the national total, which would translate into somewhere between 115K - 180K during the first week (2/15 - 2/21). Of course, CMS prefers to use "Sunday - Saturday" for their "weeks", which means the first report might only include 6 days instead of 7).

How about going forward? Well, it's 93 days from 2/15 - 5/15, or a little over 13 weeks. If you assume the pace held steady the whole time, the total SEP tally would come in somewhere between 2.1 - 3.3 million people, or between 1.4 - 2.6 million more than you'd normally expect to enroll. Needless to say, this would be dramatically higher than my 400K - 600K estimate.

Of course, the odds are that neither Health Sherpa's 40,000/week pace nor the national extrapolation of that will stay constant. Enrollment will ebb & flow as the COVID SEP period goes on; I expect the pace to drop off until early April, at which point it will likely pick back up again as people file their tax returns and get instant refunds. In several states (CA, DC, MA, NJ & RI), the ACA's individual mandate penalty is still in place; some people who weren't covered in 2020 might be nabbed by that and be inspired to make sure they get covered this time around.

Unlike the official Open Enrollment Period, which usually sees an enrollment spike in the final week, I wouldn't expect much of one the 2nd week of May, mainly because the annual deductible and maximum out of pocket ceiling stays the same even though the policy wouldn't actually start coverage until June by that point.

The other MAJOR factor, however, is again the pending American Rescue Plan bill. The current timeline seems to be to have it pass the House later this week, pass the Senate by early March and be signed into law by President Biden no later than March 14th.

Assuming that happens, it'll be a whole different ballgame. I expect there to be a significant marketing/awareness effort made by not just HealthCare.Gov but all of the state-based exchanges, and there should be a flood of mostly middle-income, 50-and-older new enrollees onto the on-exchange marketplaces to snap up subsidies for those earning more than 400% FPL...as well as a similar influx of new on-exchange enrollees among those earning less than 150% FPL, who would now be eligible for $0 premium policies nationally.

I've asked Health Sherpa if they can provide any additional data/details and will update this post as appropriate if they do so.