I have a different California-specific post coming later this afternoon, but I stumbled across a mildly interesting bit of data and figured this would be a good time to share it while I wait to be able to post that one.
As you may recall, while the ACA required that most individual market major medical healthcare policies sold have to comply with full ACA regulations, there were some exceptions to this. The biggest exception made was for major medical plans which had been continuously enrolled in since before the ACA was signed into law in March 2010.
These plans were grandfathered in, and so are appropriately called "Grandfathered Plans", and applied to perhaps 5 million people or so back in 2014, when ACA-compliance became mandatory for newly-sold policies.
IMPORTANT: As I've noted before, Covered California has arranged to expand and enhance their ACA premium subsidies beyond the official ACA formula starting with the 2020 Open Enrollment Period. Back in October, I posted a detailed analysis, complete with tables and graphs to explain just how much hundreds of thousands of Californians could save under the new, beefed-up subsidy structure.
However, Anthony Wright of Health Access California just called my attention to the fact that I made a major mistake in my analysis which impacted every one of the examples: I was basing them on the draft enhanced subsidy formula from back in May instead of the final version, which is considerably more generous at the upper end of the sliding scale than the draft version was!
In short:
The ACA formula caps premiums (for the benchmark Silver plan) at between 2 - 9.8% of household income but only if you earn between 100 - 400% of the Federal Poverty Level.
The draft California formula is a bit more generous from 100 - 400% FPL and also caps premiums between 9.9 - 25% of income between 400 - 600% FPL.
The final California formula is more generous yet: It's pretty much the same up to 400% FPL, but caps premiums between 9.8 - 18% of income between 400 - 600% FPL.
I've therefore gone back and re-calculated and re-written the entire blog post below with the updated, corrected subsidy formula. My apologies for the error!
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There's two important points for CA residents to keep in mind starting this Open Enrollment Period:
First: The individual mandate penalty has been reinstated for CA residents. If you don't have qualifying coverage or receive an exemption, you'll have to pay a financial penalty when you file your taxes in 2021, and...
Second: California has expanded and enhanced financial subsidies for ACA exchange enrollees:
Until now, only CoveredCA enrollees earning 138-400% of the Federal Poverty Line were eligible for ACA financial assistance. Starting in 2020, however, enrollees earning 400-600% FPL may be eligible as well (around $50K - $75K/year if you're single, or $100K - $150K for a family of four). In addition, those earning 200-400% FPL will see their ACA subsidies enhanced a bit.
I've made quite a bit of fuss about California expanding availability of ACA financial subsidies to those earning 400 - 600% of the Federal Poverty Line ($75K for a single person, $154K for a family of four). The subsidies aren't massive for most people, but for hundreds of thousands of Californians--especially older folks earning between 400 - 450% FPL--this is a huge savings. In addition, they're sweetening the subsidies somewhat for those already receiving ACA tax credits.
The only real concern I had about this is whether enough people in California know about it. Just like with reinstating the mandate penalty (which California has also done this year), expanding & enhancing ACA subsidies isn't gonna cause a spike in enrollment if no one knows they're available. A lot of people who might have checked into it in prior years isn't likely to bother taking another look if they don't know that the income cut-off threshold has gone up, and many others have never bothered trying in the first place because they "heard somewhere" that they won't qualify.
This press release came out last week but I covered all the other state-based exchange Open Enrollment press releases so I figured I should include this one as well:
Covered California for Small Business Announces Expanded Choices and an Average Rate Change of 4.1 Percent for 2020
I'm not sure how this slipped by me, but in addition to Covered California already having launched their 2020 Open Enrollment Period yesterday, five other state-based ACA exchanges are already partly open as well. That is, you can shop around, compare prices on next year's health insurance policies and check and see what sort of financial assistance you may be eligible for:
I'm not sure when the other 7 state-based exchanges will launch their 2020 window shopping tools, nor do I know when HealthCare.Gov's window shopping will be open for the other 38 states, although I believe they usually do so about a week ahead of the official November 1st Open Enrollment Period launch date.
I also noted that there's two important points for CA residents to keep in mind starting this Open Enrollment Period:
First: The individual mandate penalty has been reinstated for CA residents. If you don't have qualifying coverage or receive an exemption, you'll have to pay a financial penalty when you file your taxes in 2021, and...
Second: California has expanded and enhanced financial subsidies for ACA exchange enrollees:
Until now, only CoveredCA enrollees earning 138-400% of the Federal Poverty Line were eligible for ACA financial assistance. Starting in 2020, however, enrollees earning 400-600% FPL may be eligible as well (around $50K - $75K/year if you're single, or $100K - $150K for a family of four). In addition, those earning 200-400% FPL will see their ACA subsidies enhanced a bit.
While the 2020 Open Enrollment Period doesn't officially start until November 1st across the rest of the country, in California it begins two weeks earlier, for whatever reason:
In most states, open enrollment for 2020 coverage will run from November 1, 2019 to December 15, 2019. But California enacted legislation (A.B.156) in late 2017 that codifies a three-month open enrollment period going forward — California will not be switching to the November 1 – December 15 open enrollment window that other states are using.
Instead, California’s open enrollment period (both on- and off-exchange) will begin each year on October 15, and will continue until January 15. Under the terms of the legislation, coverage purchased between October 15 and December 15 will be effective January 1 of the coming year, while coverage purchased between December 16 and January 15 will be effective February 1.
Normally I write two separate annual premium rate change filing entries for each state: One when the preliminary/requested rate filings are submitted, and another one when the final/approved rates are published.
In the case of California, it turns out that the rate rview/negotiation process is...more complicated. The press release/report released by Covered California back in July referred to preliminary 2020 premiums only, but it turns out that Covered California exchange personnel had already completed all their negotiations before posting any numbers.
It also turns out (thanks to "Dena M." aka @HealthEDena) that in California, insurance policy premiums are not reviewed/approved by the state insurance department...but by an entirely different department called the Dept. of Managed Health Care, or DMHC.
*(Yes, I know, the District of Columbia isn't actually a state, and Vermont's mandate is...well, read on...)
As the 2020 Open Enrollment Period rapidly approaches (it starts November 1st nationwide...except for California, where open enrollment is starting on October 15th), it's time to start getting the word out about some important things to keep in mind this fall.
One of the most critical things to remember for residents of California, the District of Columbia, Massachusetts, New Jersey, Rhode Island and Vermont is that each of these states* has reinstated an individual healthcare coverage mandate law/ordinance to replace the federal ACA mandate penalty which was zeroed out by Congressional Republicans back in December 2017. This means that if you live one one of them, unless you receive an affordability, hardship or other type of acceptable exemption, you'll be charged a financial penalty when you file your state/district taxes for 2020 in spring 2021 if you don't have qualifying healthcare coverage.
But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:
