This just in...and it relates directly to my prior post just a couple of hours ago about Alabama finally implementing their own Effective Rate Review program this year. Just moments ago, the HHS Dept. issued this press release:

CMS Announces $22 Million in Affordable Care Act Funding for State Insurance Departments
Awards will help states enforce Affordable Care Act consumer protections

Alabama

As I noted this morning, while I've managed to track down the requested rate hikes for 31 states & DC so far, the remaining 19 states could take awhile. Michigan won't be posting theirs for another week or so, other states could be longer...and then there's Alabama:

Health insurance companies that want to raise rates more than 10 percent next year will get an extra dose of scrutiny from Alabama regulators this year – for the first time since the marketplace launched in 2013.

Under Obamacare, states were supposed to implement systems for reviewing, and in some cases rejecting, rate increases that exceed 10 percent. Alabama was one of six states that didn't create an effective rate review program, despite receiving a $1 million grant to bolster oversight at the Department of Insurance, according to the Centers for Medicare & Medicaid Services.

After crunching the numbers for the requested rate changes (OK, rate hikes) across 31 states & DC, it looks like it's gonna be awhile longer for the remaining 19 states to post their rate filings publicly. For instance, while Michigan's SERFF database has had a whole mess of rate filing stuff posted for weeks now, none of them appear to include the two pieces of crucial data that I need for this project: The actual requested average percentage rate changes and the actual number of current lives covered by those policies...and likely won't for at least another week:

2017 Rate Filings - Individual Products - ALERT

The 2017 Individual Product filings are not yet complete. Partial filing information was submitted by issuers on May 9, 2016.

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!!

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