New York: @NYStateofHealth *finally* releases 2021 Open Enrollment report; QHPs/CHIP down; BHP/Medicaid up

In previous years, New York State of Health has typically been pretty good about providing timely Open Enrollment reports, so I was mildly irritated by their total radio silence on the issue throughout the 2021 Open Enrollment Period (OEP).

My suspicion was that, like many other states which have expanded Medicaid, New York likely saw a significant drop in on-exchange Qualified Health Plan (QHP) enrollment this season due to the massive job & income loss caused by the COVID-19 pandemic last year, as people "downshifted" from QHPs over to Medicaid. In addition, New York is one of only two states which has the ACA's Basic Health Program (BHP) in place; BHP (called the Essential Plan in NY), is sandwiched in between QHPs and Medicaid, for residents earning between 138 - 200% FPL.

Late last night, NYSoH finally got around to releasing their 2021 OEP numbers. Sure enough, my suspicions were correct:

Press Release: NY State of Health Announces Enrollment Surges, More than 5.8 Million New Yorkers Enrolled in Health Coverage

• Nearly One in Three New Yorkers Enrolled Through NY State of Health
• High-Quality Health Insurance More Important Than Ever as Pandemic and Vaccine Response Continues

ALBANY, N.Y. (March 9, 2021)—NY State of Health, the state’s official health plan Marketplace today announced, across all Marketplace programs, enrollment increased by nearly 885,000 people from the end of the 2020 Open Enrollment Period in February 2020 to the end of February 2021. There are now a record 5.8 million people enrolled in coverage through NY State of Health – nearly one in three New Yorkers.

“While it could not have been envisioned at the time, because of New York’s unwavering commitment to its implementation of NY State of Health, expanding Medicaid, and adopting the Essential Plan for lower-income New Yorkers, the Marketplace has served as a safety net for consumers during this public health emergency,” said NY State of Health Executive Director, Donna Frescatore. “Without easy, real-time access to these programs, many would not have had access to affordable health care throughout the past year, as the state responded to the global COVID-19 pandemic.”

Enrollment increases over the past year were concentrated in Medicaid and the Essential Plan in line with expectations, as individuals lost their jobs and/or saw sharp declines in their incomes during the pandemic. As household income changed, NY State of Health allowed for smooth transitions from Qualified Health Plan and Child Health Plus enrollment to Medicaid and Essential Plan, often in the same health plan. Marketplace enrollees in 2021 include both individuals who are new to the Marketplace and were previously uninsured or had other coverage, and individuals who moved between NY State of Health programs due to a change in circumstances, such as loss of income.

NY State of Health Enrollment, as of February 28, 2021:

• Medicaid*: 4,312,895
• Child Health Plus: 391,348
• Qualified Health Plans: 214,365
• Essential Plan: 885,012
• Total: 5,803,620

*Total Medicaid enrollment on and off NY State of Health is 6,815,777 as of December 2020.

There's several important things to note here:

First, instead of measuring enrollment as of January 31st of each year, they're comparing enrollment as of the end of February 2021 against February 7th 2020. This gets into a bit of a weird area, because last year they tacked on an extra week for no particular reason (COVID hadn't hit yet), while this year, due to the COVID-19 pandemic, the "official deadline" for 2021 technically hasn't ended yet. NYSOH announced back on 1/21 that they were extending Open Enrollment through March, and later on they announced they were matching the federal COVID Enrollment Period which runs through May 15th.

Even so, they really should have used 1/31 as the "end date" this year for purposes of this particular report...or at the very least, 2/07 to match last year.

The other thing to note is the emphasis on total NYSOH enrollment being up significantly. Most other states only run Qualified Health Plans (QHPs) through their ACA exchanges; those qualifying for Medicaid or CHIP are redirected towards other online systems. In New York, CHIP is run through the exchange itself, and they've been gradually shifting all Medicaid enrollees over to the NYSOH system as well. In addition, as noted above, NYSOH has a BHP program which generally has around 3x as many enrollees as QHPs.

As a result, it makes sense for NYSOH to lump all of these numbers together in the headline...especially if enrollment in QHPs (which are the "main" numbers most people think of when considering ACA enrollment) is down significantly year over year...which is exactly the case here:

As you can see, QHP enrollment is down over 21% y/y, by over 58,000 people, and (more surprisingly) CHIP enrollment is also down over 13%. On the other hand, Essential Plan (BHP) enrollment is up 11%, or over 88,000 people...and since the BHP program covers those who would otherwise have enrolled in QHPs, this makes for a net increase in the "QHP market" if you will (those earning 138% FPL or higher).

Medicaid enrollment, meanwhile, exploded as expected, increasing by a whopping 29% y/y via NYSOH. To be fair, this isn't quite accurate since, as I noted above, New York has been gradually shifting their Medicaid enrollees from a legacy system over to the NYSOH database; as shown above, enrollment via their old platform dropped 6.4% from February 2020 - December 2020 (that's the most recent date I have a full NY Medicaid tally for...it's also the number reported in the press release). Even so, total Medicaid enrollment still increased by 12.3% as of the end of 2020 (745,000), and has likely gone up a bit more since then.

I have no idea how the Centers for Medicare & Medicaid (CMS) are going to report NY's data in their official 2021 OEP report, to be honest. Will they cut the report off as of 1/31, or will they use this 2/28 figure instead? If they do so, that would make it difficult not to do the same for every other state, since the current COVID Enrollment Period started up again on 2/15, and so on. If I were writing the report, I'd make 1/31/21 the formal end date regardless.

In any event, with this press release, Rhode Island remains the only state which hasn't provided any 2021 Open Enrollment data to date.

As previously announced, New York’s 2021 Open Enrollment Period has been extended to May 15, 2021 in alignment with the ongoing federal public health emergency. Ensuring access to affordable health coverage and care is more important than ever, so that individuals do not avoid seeking testing or medical care for fear of cost. Most marketplace enrollees qualify for financial assistance to lower the cost of their coverage. This deadline extension allows individuals eligible for Qualified Health Plan insurance additional time to enroll for 2021 coverage. Enrollment remains open for all NY State of Health programs.

Coverage start dates will vary:

• Enroll by March 15: Coverage starts April 1
• Enroll by April 15: Coverage starts May 1
• Enroll by May 15: Coverage starts June 1

Individuals who are eligible for other NY State of Health programs—Medicaid, Essential Plan and Child Health Plus—can enroll year-round. As always, consumers can apply for coverage through NY State of Health online at nystateofhealth.ny.gov, by phone at 1-855-355-5777, or by connecting with a free enrollment assistor.