a) No complete overhaul of the U.S. healthcare system is going to happen before 2021 at the very earliest anyway; and
b) Regardless of what the hypothetical overhaul ended up looking like (M4All, Med4America, or a Public Option), it would likely take a couple of years of going through the legislative and regulatory process before actually going into effect; and that therefore...
c) In the short term (i.e., the next 2-3 years at least) what we should really be focusing on is protecting, repairing and strengthening the ACA itself, via a robust ACA 2.0 bill package.
As I reminded folks, there are two excellent ACA 2.0 bills which have already been introduced in both the House and Senate, with many overlapping provisions: In the House, it's H.R. 1884...which has also in turn been broken out into about a dozen smaller, standalone bills (several of which have already passed through the full House). In the Senate, it's S.1213, the Consumer Health Insurance Protection Act or CHIPA. As far as I know, the Senate version is a single package bill and has not been broken out into smaller chunks.
I've written endlessly about #ShortAssPlans for several years now. Hell, I even put together a crude video explainer (see above) to explain what "Short-Term, Limited Duration plans" and "Association Health plans" are and why they should be tightly regulated, if not eliminated altogether.
However, the truth is that for all of my blog posts and warnings about these types of substandard policies, about 90% of my focus has been on how opening up the floodgates on them would negatively impact the ACA-compliant risk pool. It's a bit of a zero-sum game, after all: The more healthy people who leave one, the more sick on average the other one is, which means a higher risk pool of enrollees, which means higher premiums, which leads to more healthy people dropping out and so on...the infamous "death spiral".
What I've written much less about, however, is the other reason why #ShortAssPlans generally suck...namely, the plans themselves tend to...well, suck.
I spent the past few weeks up to my ears in Medical Loss Ratio analyses, so a lot of ACA/healthcare developments slipped by or got backlogged. There were stories which are technically separate but which are pretty obviously joined at the hip...and the fact that they both came out right on top of each other is pretty telling.
The Health 202: White House may have given up on health plan it says it is writing
A former White House staffer and several congressional aides and activists say they’ve been told the Trump administration has moved away from seeking an Obamacare replacement and is instead focused on damage control should a judge rule next month to topple the entire law.
OK, OK, I know I said I was sick of writing about MLR rebates, but there's one more important point I need to mention...and while I'm at it, I also said "to hell with it" and recompiled the rebate tables for all 50 states into a single massive table listing every carrier offering rebates in every state.
While I applaud the ACA's Medical Loss Ratio Rebate provision overall, there's one important flaw in how it works. I've made allusions to this before, and last week David Anderson wrote a blog post specifically about it, but it bears repeating here: Due to an oversight in the wording of the section of the ACA devoted to laying out MLR rebates, some subsidized individual market enrollees are actually PROFITING off the program.
The reason why is pretty simple: The individual market MLR rebate payments are sent, in full, to the policyholder regardless of whether or not their premiums are being subsidized by the federal government or not.
One of the interesting quirks of how the Affordable Care Act's enhancement of our crazy patchwork heatlhcare system works is that there's something of a zero-sum game when it comes to enrollment numbers.
For instance, Virginia's ACA exchange enrollment numbers dropped by 18% this year, from 400,000 to 328,000, due primarily to the state finally getting around to expanding Medicaid to enrollees earning less than 138% of the Federal Poverty Level. Since people earning between 100-400% FPL are eligible for ACA subsidies if they enroll through the exchange, that means there's an overlap for those in the 100-138% range which these folks fell into. The same thing happened in Louisiana, even more dramatically, after they expanded Medicaid halfway through 2016...the following year exchange enrollment dropped by 33%.
Last month I noted that North Dakota had posted their requested 2020 premium rate change requests, including two different filings: One assuming the states' ACA Section 1332 Reinsurance Waiver didn't get approved, the other assuming it did. It was pretty unlikely that their waiver would be denied, however, so the general assumption was that they'd be looking at a significant rate reduction, especially compared with the rate increase if the waiver didn't go through.
At the time, I didn't have access to the actual enrollment figures for the three carriers on North Dakota's individual market, so I had to go with an unweighted average rate change, and came up with a drop of 7.9%.
Insurance Commissioner Issues Decisions For 2020 Health Insurance Rates
Insurance Commissioner Andrew N. Mais today announced the Department has made final decisions on health insurance rate filings for the 2020 coverage year. As a result of these decisions, Connecticut consumers are projected to save approximately $54 million.
Back in early June, the Washington State Insurance Commissioner announced that preliminary rate filings for the ACA individual market in 2020 were averaging just 1.0% higher than this year. My own analysis brought the weighted average in at 1.4%, but whatever. The Small Group market requests also came in at an average increase of 6.7%.
With my big MLR Rebate project finally out of the way, I have a backlog of other write-ups, including several approved 2020 premium rate changes. First up is tiny Rhode Island.
As you may recall, back in July the Rhode Island insurance commissioner announced that the state was following New Jersey's model: They're reinstating the individual mandate penalty, and using the revenue from that to help fund their just-approved state reinsurance program to reduce unsubsidized premiums by 5-6 percentage points:
If approved, Rhode Island would have a $14.7 million reinsurance program for 2020 funded through the individual mandate penalty and federal pass-through funding. Rhode Island estimates a federal pass-through rate of 43 percent. Of the $14.7 million, the federal government would contribute less than half of the funds (about $6.4 million), and the state would contribute about $8.3 million.
If you've been reading the site recently, you know that I've been obsessed for the past 2-3 weeks with nothing but the 2018 Medical Loss Ratio rebate payments.
Now that I've completed posting my analyses of all 50 states (+DC), I'm wrapping it up with a table summarizing the the totals for the entire country, how it compares with the Kaiser Family Foundation's similar report posted a few days ago, and some additional thoughts and observations which have come to mind in doing this project.
We at KFF put out an analysis today of how much insurers will be paying in rebates to consumers and employers later this month. @charles_gaba also has very good information on this, and we all benefit from his tireless tracking. https://t.co/uPX2SPklcY
