Charles Gaba's blog

Thanks to Richard Mayhew of Balloon Juice for bringing this to my attention: This morning, Sabrina Corlette and JoAnn Volk of the Center on Health Insurance Reforms posted an amusing but also highly educational real-world example of the sort of non-ACA compliant healthcare plans that outfits like "Freedom Life" (aka "National Foundation" aka "Enterprise Life" aka "USHealth") specialize in...which also happen to be the exact types of plans that HHS is trying to keep a lid on with their recently-announced policy change.

From Corlette/Volk:

Gun rights activists are constantly criticizing gun safety activists for not understanding the distinction between an "automatic" weapon, a "semi-automatic" weapon, a "machine gun", an "assault rifle" and so forth. I admit that I know very little about guns other than that their primary purpose...their only purpose, really...is to either kill or wound people or animals or, alternatively, to threaten to kill or wound.

Gun rights activists also constantly point out that you can kill/injure people with other items, such as knives, baseball bats, box cutters and so forth. This is true. However, unlike guns, those items actually have a useful primary purpose besides to kill or injure. If you remove baseball bats from someone's hands, they can't play baseball. If you remove knives from their hands, they can't slice bread.

If you remove a gun from their hands, the only thing they can't do is...shoot stuff.

By my count, Tennessee has a total of 6 companies offering individual policies this year (Aetna, TRH, BCBS of TN, Cigna, "Freedom Life" (hah!) and Humana. UnitedHealthcare is dropping out next year, leaving at least 37,000 people to switch to a different policy (this is based on this article in the Tennessean, which claims that United currently has 15.76% of the On-exchange individual market in Tennessee). TN had 269,000 people select exchange-based QHPs during the 2016 open enrollment period. Assuming around 13% net attrition since then, that leaves around 234,000 current enrollees on the exchange. If United holds 15.76% of those, that's around 37,000 poeple.

Hmmmm...I'm still waiting for the Michigan Dept. of Insurance to publicly post the 2017 requested rate hikes (they aren't due until June 20th, apparently), but in the meantime, Blue Cross Blue Shield of Michigan (the largest insurer in the state) decided to issue a press release patting themselves on the back for keeping their small business average rate hike down to 2.9%:

DETROIT, June 8, 2016 /PRNewswire-USNewswire/ -- In contrast to national trends, Blue Cross Blue Shield of Michigan today announced a comparatively small statewide average rate increase of 2.9 percent for small group employers in 2017, pending state regulatory approval. This follows rate reductions that Blue Cross delivered to small employer group customers that renewed during the second half of 2015.

Interesting. When I last checked in on the Maryland exchange, their effectuated QHP enrollment was down about 14% since the end of open enrollment (from 162,177 QHP selections to 139,379 effectuated enrllees as of the end of April).

However, they just posted the following market share breakdown, which shows that they currently have 148,403 Marylanders enrolled in exchange policies, a net drop of just 8.5%. Apparently they've added more people during the off season via SEPs than they've lost due to attrition since April.

Back in April, I attempted to figure out just how many people are still enrolled in Grandathered and/or Transitional (or "Grandmothered") policies on the individual market. My conclusion, based on some very rough estimates, was that the figure is likely somewhere between 800K - 1.4 million Grandfathered enrollees and somewhere between 1.1 - 1.5 million Transitional enrollees.

Today, I decided to try tackling the Transitional side of this problem by taking the direct approach: I visited RateReview.Healthcare.Gov.

Most of my time spent here over the past few weeks has been spent on the "Search ACA-Compliant Products" side, trying to lock down the requested 2017 rate hikes for every carrier offering individual policies in every state. However, there's a second big button available as well: "Search Transitional Products":

I receive most of the HHS/CMS press releases, but this one seems to have slipped by me (furiously checking spam filter...). Fortunately, Bob Herman of Modern Healthcare spilled the beans via Twitter this morning (emphasis mine):

Today, the Department of Labor, Department of Treasury, and Department of Health and Human Services (HHS) issued a proposed rule to revise the definition of short-term, limited duration coverage. Under the new rules, short-term policies may be offered only for less than three months, and coverage cannot be renewed at the end of the three month period. The proposed rule also improves transparency for consumers by requiring issuers to provide notice to consumers that the coverage is not minimum essential coverage, does not satisfy the health coverage requirement of the ACA, and will not prevent the consumer from owing a tax penalty. The proposed changes will help strengthen the risk pool by ensuring that short term limited duration plans are used only as intended, to fill truly temporary gaps in coverage.

First, let's hear it for the Oxford Comma, everyone!!

Ever since my infamous clash with Avik Roy over the "how many exchange enrollees are newly insured?" brouhaha over two years ago, one issue which has always been kind of fuzzy has been the question of exactly how many OFF-exchange individual healthcare policy enrollees there are. Since most carriers don't like to break out their enrollment numbers in too much detail for competitive/trade secret reasons, and many states don't require them to do so, this makes tracking the off-exchange numbers pretty difficult.

Having said that, Mark Farrah & Associates (via the Kaiser Family Foundation) has done the legwork to try and figure this number out, and according to them, after floating between 10.6 - 10.9 million for several years prior to the ACA exchanges launching, the total individual market (which includes exchange-based and OFF-exchange enrollees) shot up to 15.6 million in 2014.

According to this study:

Just yesterday I posted the Washington Healthplanfinder's latest monthly report, which showed either 177,613, 170,267 or 167,827 people currently enrolled in exchange QHPs statewide, depending on whether you go by the number who have "selected plans", the number that the carriers have reported as being paid up or the number who the exchange has recorded as having paid.

The first number has been pretty confusing to me over the past few months, because the actual number of people who selected QHPs during the 2016 open enrollment period was reported as just over 200,000 by both the exchange itself as well as in the official national ASPE report, so I wasn't quite sure whether to report the net effectuated enrollment drop since then as being almost none at all or around 15%. I finally went with the 15% figure because dividing into the 177K number just didn't make sense by any other measure.

There are only 2 things I'm certain of when it comes to the requested rate hike filings in Arizona's individual market:

  1. It's a confusing mess.
  2. Regardless of #1, Arizona's requested rate hikes are jaw-dropping even when weighted by carrier.

The data below is drawn from two sources: The RateReview.HealthCare.Gov database and Arizona's Health Filing Access Interface (HFAI) SERFF database.

As you can see, there's some confusing and contradictory numbers, but I'll try to muddle through each:

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