HC.gov

Note: A few weeks ago, I ran a rough back-of-the-envelope extrapolation of partial data from the first 2 weeks of the ongoing COVID Special Enrollment Period and concluded that IF enrollment via the 36 HealthCare.Gov states was representative nationally, and IF the pace of the last 2 weeks of February held perfectly steady, it would mean around 666,000 new enrollees via HC.gov and 832,000 nationally by the end of March. Those were two pretty big caveats, of course, and as you'll see below, the reality wasn't quite as eyebrow-raising, though it's still pretty impressive.

This just in via the Centers for Medicare & Medicaid Services (CMS):

2021 Marketplace Special Enrollment Period Report

February 15 – March 31, 2021

This morning, Vox reporter Dylan Scott posted a story touting exclusive access to a new ASPE analysis which estimates nearly 7 million uninsured Americans who now qualify for a FREE ($0 premium) ACA health insurance policy, in large part thanks to the American Rescue Plan's expanded subsidies:

Roughly 29 million people currently living in the US lack health insurance. According to the new HHS estimates, about 6.8 million of them could now purchase an ACA plan with no monthly premium, and another 1.3 million could sign up for a health plan that costs less than $50 a month. Many of those people already qualified for free or low-cost coverage prior to the ARP, but based on the federal projections, the new law’s expansion of the ACA made an additional 2 million Americans eligible for free or cheap coverage.

June 16, 2020:

On March 20th, the Vermont Health Connect ACA exchange joined other state-based exchanges in launching a formal COVID-19 Special Enrollment Period.

On April 15th, just ahead of the original SEP deadline, they bumped it out by a month.

Then, with the May deadline approaching, I took a look and sure enough, they've bumped it out another month.

And now, with the June deadline having come and gone...

Due to the COVID-19 emergency, Vermont Health Connect has opened a Special Enrollment Period until August 14, 2020.

I admit that this is starting to get a bit silly. At a certain point I'm guessing at least one of the state exchanges will just say "screw it" and open 2020 enrollment up for the full year.

The Centers for Medicare & Medicaid Services (CMS) has just sent out guidance about how the newly-expanded & enhanced subsidies will work for those currently enrolled in (or newly enrolling in) healthcare policies via the federal ACA exchange, HealthCare.Gov.

It's important to note that the following guidelines only apply to residents of the 36 states hosted via HC.gov. The timing, policy and procedures for the new/expanded subsidies for residents of the 15 states which operate their own ACA exchanges may vary.

With that in mind, here's how CMS says things will work via HealthCare.Gov.

The first section is mostly just an overview of the ARP and a refresher on how ACA subsidies are calculated...

American Rescue Plan and the Marketplace

The New Law

Back in late January, when it became clear that the Biden Administration was planning on announcing some sort of "no excuse needed" COVID Special Enrollment Period for the federal ACA exchange, I did a little back-of-the-envelope math to try and get an idea of how many additional people might enroll via HealthCare.Gov than you'd normally see via "standard" Special Enrollment Periods.

At the time, I concluded that for a 60-day SEP of this nature (that is, one completely open to all comers regardless of whether they had a Qualifying Life Experience (QLE)or not), you might be looking at perhaps an extra 400,000 people. selecting plans during that time period. This would be on top of the 4,200/day who enrolled thru HC.gov between the end of Open Enrollment and the end of May via SEPs over the past couple of years, which would be roughly 254,000 for a 60-day period.

via the Centers for Medicare & Medicaid:

2021 Special Enrollment Period for Marketplace Coverage Starts on HealthCare.gov Monday, February 15

  • SEP allows consumers to enroll in affordable health coverage during the COVID-19 Public Health Emergency

 Today, in accordance with the Executive Order signed by President Biden, the Centers for Medicare & Medicaid Services (CMS) is announcing that the Special Enrollment Period (SEP) for the Health Insurance Marketplace® will officially be available to consumers in the 36 states that use the HealthCare.gov platform on Monday, February 15, and will continue through Saturday, May 15. At least 13 States plus the District of Columbia, which operate their own Marketplace platforms, have decided to offer a similar opportunity.

As I noted earlier today, the Big News® this today is President Biden's pending Executive Order to re-open HealthCare.Gov to a full 3-month COVID-19 Special Enrollment Period starting on February 15th. There's a whole bunch of other important stuff in today's healthcare XO, but some of them will take months to actually finalize and implement.

Frankly, re-opening HC.gov is actually one of the simplest and most obvious healthcare-related executive orders Biden could give at the moment. Now that the starting/ending dates are known, it raises one other important question.

I wrote about this a few days ago, but today it'll be official:

President Biden to Sign Executive Orders Strengthening Americans’ Access to Quality, Affordable Health Care

The Biden-Harris Administration will open a Special Enrollment Period for Americans to sign up for health coverage and roll back attacks on the Affordable Care Act, Medicaid, and access to reproductive health care

Strengthening Medicaid and the Affordable Care Act.

UPDATE: It's official...and it'll be 90 days starting on 2/15, not 60.

In an news which surprises absolutely no one, this Thursday the Biden Administration is expected to officially announce a COVID-19 Special Enrollment Period at HealthCare.Gov, the federal ACA exchange which hosts enrollment for 36 states:

Thursday: ‘Health Care’ day

...The president is also slated to sign an executive order aimed at strengthening Medicaid and initiating an open enrollment period under the Affordable Care Act.

Trump frequently bragged about gutting the Affordable Care Act by rescinding the individual mandate, though Republicans were unable to fully repeal the law as promised.

Regular readers (and some non-regular readers) may recall that in the week between Christmas and New Year's Eve, I put out an urgent "call to action" request for people to submit Public Comment on the proposed annual Notice of Benefit & Payment Parameters for 2022 (NBPP) rule.

As I explained, every year, the Centers for Medicare & Medicaid (CMS) puts together a bunch of proposed modifications to the implementation details of the ACA. Some are simple clarifications of existing procedures; some are minor tweaks; and some are major changes. Of the major changes, some are positive...and some are negative. In the case of the 2022 NBPP, there are examples of all three...and the major changes are really major. As in, ranging from harmful to likely flat-out illegal.

For 2022, there were several NBPP items which seem either innocuous or are actually good ideas...but there are a couple of pretty questionable ones and a few more which would be outright devastating (there are also a few involving things like Risk Adjustment which I'm not familiar enough with to comment on one way or the other).

Hot off the presses, via the Centers for Medicare & Medicaid:

Final Snapshot, November 1 - December 21, 2020

Approximately 8.3 million people selected or were automatically re-enrolled in plans using the HealthCare.gov platform during the 2021 Open Enrollment period.

These snapshots provide point-in-time estimates of weekly plan selections, call center activity and visits to HealthCare.gov or CuidadoDeSalud.gov. The final snapshot reports new plan selections, active plan renewals and automatic renewals. It does not report the number of consumers who paid premiums to effectuate their enrollment.

As a reminder, New Jersey and Pennsylvania transitioned to their own State-based Exchange platforms for 2021, thus they are not on the HealthCare.gov platform for 2021 coverage. Those two states accounted for 578,251 plan selections or 7% of all plan selections during the 2020 Open Enrollment Period. Plan selections for 2021 coverage in these two states will not appear in our figures until we announce the State-based Exchange plan selections.

UPDATE 12/31/20: The deadline to submit public comments has passed. In the end, there are 320 comments, 243 of which were submitted after I posted this entry. The wording on a random check of some finds that at least a couple dozen appear to have been guided by my own sample comment below, which I'm glad to see.

Now we'll just have to wait and see. Thank you to everyone who helped out!

Last month, I wrote about the annual Notice of Benefit & Payment Parameters for 2022 (NBPP) from the Centers for Medicare & Medicaid (CMS). This is a long, wonky document published each year which includes a bunch of proposed modifications to various aspects of how the ACA is administered and implemented.

Some of the proposed changes each year are pretty much mandatory. Some are completely up to whoever is running CMS/HHS at the time. Some are nominal tweaks; some are major changes.

Hot off the presses, via the Centers for Medicare & Medicaid:

Week Six, December 6 - December 15, 2020

In Week Six of the 2021 Open Enrollment period, 4,416,057 people selected plans using the HealthCare.gov platform or were automatically re-enrolled in a plan. While past snapshots this year have measured enrollment weeks Sunday through Saturday, this week’s snapshot for week six also includes the final few days of the Open Enrollment Period.

Hot off the presses, via the Centers for Medicare & Medicaid:

Week Five, November 29 - December 5, 2020

In Week Five of the 2021 Open Enrollment period, 915,118 people selected plans using the HealthCare.gov platform. As in past years, enrollment weeks are measured Sunday through Saturday.

Every week during Open Enrollment, the Centers for Medicare & Medicaid Services (CMS) will release enrollment snapshots for the HealthCare.gov platform, which is used by the Federally-facilitated Exchange and some State-based Exchanges. These snapshots provide point-in-time estimates of weekly plan selections, call center activity, and visits to HealthCare.gov or CuidadoDeSalud.gov.

The final number of plan selections associated with enrollment activity during a reporting period may change due to plan modifications or cancellations. In addition, the weekly snapshot only reports new plan selections and active plan renewals and does not report the number of consumers who have paid premiums to effectuate their enrollment.

Hot off the presses, via the Centers for Medicare & Medicaid:

Week Four, November 15 - November 28, 2020

In Week Four of the 2021 Open Enrollment period, 523,020 people selected plans using the HealthCare.gov platform. As in past years, enrollment weeks are measured Sunday through Saturday.

Every week during Open Enrollment, the Centers for Medicare & Medicaid Services (CMS) will release enrollment snapshots for the HealthCare.gov platform, which is used by the Federally-facilitated Exchange and some State-based Exchanges. These snapshots provide point-in-time estimates of weekly plan selections, call center activity, and visits to HealthCare.gov or CuidadoDeSalud.gov.

The final number of plan selections associated with enrollment activity during a reporting period may change due to plan modifications or cancellations. In addition, the weekly snapshot only reports new plan selections and active plan renewals and does not report the number of consumers who have paid premiums to effectuate their enrollment.

Hot off the presses, via the Centers for Medicare & Medicaid:

Week Three, November 15 - November 21, 2020

In Week Three of the 2021 Open Enrollment period, 758,421 people selected plans using the HealthCare.gov platform. As in past years, enrollment weeks are measured Sunday through Saturday. 

Every week during Open Enrollment, the Centers for Medicare & Medicaid Services (CMS) will release enrollment snapshots for the HealthCare.gov platform, which is used by the Federally-facilitated Exchange and some State-based Exchanges. These snapshots provide point-in-time estimates of weekly plan selections, call center activity, and visits to HealthCare.gov or CuidadoDeSalud.gov.

The final number of plan selections associated with enrollment activity during a reporting period may change due to plan modifications or cancellations. In addition, the weekly snapshot only reports new plan selections and active plan renewals and does not report the number of consumers who have paid premiums to effectuate their enrollment.

Hot off the presses, via the Centers for Medicare & Medicaid:

Week Two, November 8-November 14, 2020

In Week Two of the 2021 Open Enrollment period, 803,741 people selected plans using the HealthCare.gov platform. As in past years, enrollment weeks are measured Sunday through Saturday. 

Every week during Open Enrollment, the Centers for Medicare & Medicaid Services (CMS) will release enrollment snapshots for the HealthCare.gov platform, which is used by the Federally-facilitated Exchange and some State-based Exchanges. These snapshots provide point-in-time estimates of weekly plan selections, call center activity, and visits to HealthCare.gov or CuidadoDeSalud.gov.

The final number of plan selections associated with enrollment activity during a reporting period may change due to plan modifications or cancellations. In addition, the weekly snapshot only reports new plan selections and active plan renewals and does not report the number of consumers who have paid premiums to effectuate their enrollment.

Every Open Enrollment Period (OEP) for for the past several years, the Centers for Medicare & Medicaid (CMS) have issued a Weekly Snapshot Enrollment Report including the top-line Qualified Health Plan (QHP) enrollment data via HealthCare.Gov for that week along with the cumulative totals. They normally post these reports, which run Sunday - Saturday, on the following Wendesday...but yesterday came and went without one being released this year.

Given the insanity surrounding last week's Presidential election (along with the results) and the ongoing COVID19 pandemic, I was beginning to wonder whether they'd bother issuing those reports at all. Fortunately, they followed through late this afternoon:

Week 1, November 1-November 7, 2020

In week one of the 2021 Open Enrollment period, 818,365 people selected plans using the HealthCare.gov platform. As in past years, enrollment weeks are measured Sunday through Saturday. 

Me, 3/31/20, 1:14pm:

Well, today I received a likely answer which is depressing but not surprising at all: According to my sources, there isn't any technical, logistical, personnel or support reasons why HealthCare.Gov couldn't launch a formal COVID-19 Special Enrollment Period at any time. The only logical conclusion is that the White House has decided not to allow one for political reasons.

...The more people who come to rely on the Affordable Care Act--especially the ACA exchange operated by the Trump Administration itself--the more difficult it's going to be to justify the Trump Administration continuing to support a lawsuit with the sole purpose of attempting to have the ACA struck down by the Supreme Court...which they're continuing to try and do even in the middle of a pandemic.

Susannah Luthi, Politico, 3/31/20, 5:19pm:

Trump rejects Obamacare special enrollment period amid pandemic

Three weeks ago I reported that there were growing calls from many quarters for CMS Administrator Seema Verma and HHS Secretary Alex Azar to open up a federal Special Enrollment Period at HealthCare.Gov tied specifically to the COVID-19 pandemic.

Over the next week or so, more and more of the 13 state-based ACA exchanges announced just such a COVID-19 SEP; eventually 12 out of 13 state-based exchanges did so (Idaho is the odd man out), and eventually even the health insurance industry (which is normally opposed to allowing exceptions to the official Open Enrollment Period) were onboard with a COVID SEP. Two weeks ago I was 95% certain that HC.gov would be announcing one at any moment.

And then...nothing. Nothing last week. Nothing yesterday. Nothing as of this writing.

One week ago, in light of the growing COVID-19 crisis, I noted that California, the District of Columbia and Maryland were each offering Special Enrollment Periods which had nothing whatsoever to do with the pandemic.

California's SEP is for uninsured residents who didn't know that the state had reinstated the individual mandate penalty and expanded financial subsidies to those earning 400-600% of the Federal Poverty Line; DC is offering one for those who didn't know they had also reinstated the mandate penalty; and Maryland passed a clever law last year which lets residents check a box when they file their state taxes if they're uninsured which tells the state to contact them to help them enroll.

I concluded that:

...as far as I know, there's nothing preventing other state-based exchanges from establishing Special Enrollment Periods for the coronavirus crisis if they want to.

Earlier today, CMS quietly issued the FINAL 2020 Open Enrollment Period HealthCare.Gov "Snapshot Report":

Final Snapshot: Nov 1-Dec 21

Approximately 8.3 million people selected or were automatically re-enrolled in plans using the HealthCare.gov platform during the 2020 open enrollment period.

These snapshots provide point-in-time estimates of weekly plan selections, call center activity and visits to HealthCare.gov or CuidadoDeSalud.gov. The final snapshot reports new plan selections, active plan renewals and automatic enrollments. It does not report the number of consumers who paid premiums to effectuate their enrollment.

As we do each year, CMS also plans to release a detailed 2020 final enrollment report in March, including final plan selection data from State-based Exchanges that do not use the HealthCare.gov platform.

Normally the Weekly HC.gov Snapshot Reports are released on Wednesdays. This week it was delayed until Friday in order to include the extra 2 1/2 days:

  • The final official day (Dec. 15th) fell on a Sunday this year
  • The additional 36 hour extension from 3pm on Monday 12/16 - midnight Eastern on Wednesday 12/18*

Not only is "Week 7" actually 9.5 days, but the final week of Open Enrollment also always includes a last-minute enrollment surge as people scramble to beat the deadline (both the original and the extension). In addition, it's also traditionally the week that CMS adds all of the auto-renewals to the report for current enrollees who neither actively selected a policy for 2020, nor did they cancel their coverage for the new year.

As a result of these factors, the numbers for Week 7 understandably dwarf each of the previous snapshot reports:

Week 7, Dec 8-17, 2019

The Week 6 HealthCare.Gov Snapshot Report from CMS should be released sometime Wednesday afternoon, covering enrollment in 38 states from Dec. 1st - 7th.

As a reminder, here's what the Week 5 report looked like (for Nov. 1st - 30th):

There are two major things to account for when comparing the two years: First, there's a day missing due to Nov. 1st falling on a Friday instead of a Thursday this year. This likely accounts for around ~120,000 of the difference. Secondly, Nevada split off from HC.gov this year, which accounts for around ~19,000 of the gap the first 3 weeks. In addition, a small portion of the difference is likely due to Idaho and Maine expanding Medicaid; exchange enrollees earning between 100-138% FPL should be tranferred over to Medicaid instead.

The Week 4 HealthCare.Gov Snapshot Report from CMS should be released at any time, covering enrollment in 38 states from Nov. 10th - Nov. 23th.

As a reminder, here's what the Week 3 report looked like:

There are two major things to account for when comparing the two years: First, there's a day missing due to Nov. 1st falling on a Friday instead of a Thursday this year. This likely accounts for around ~120,000 of the difference. Secondly, Nevada split off from HC.gov this year, which accounts for around ~19,000 of the gap the first 3 weeks. In addition, a small portion of the difference is likely due to Idaho and Maine expanding Medicaid; exchange enrollees earning between 100-138% FPL should be tranferred over to Medicaid instead.

The Week 3 HealthCare.Gov Snapshot Report from CMS should be released later on this afternoon, covering enrollment in 38 states from Nov. 10th - Nov. 16th.

As a reminder, here's what the Week 2 report looked like:

There are two major things to account for when comparing the two years: First, there's a day missing due to Nov. 1st falling on a Friday instead of a Thursday this year. This likely accounts for around half of the 244,000 difference. The other significant difference is that Nevada split off from HC.gov this year, which accounted for around 12,000 of the gap the first 2 weeks.

If you assume around 130,000 of the difference is due to the missing day, that still leaves 2020 Open Enrollment around 100,000 short of the same time period last year on HealthCare.Gov.

This Just In from the Centers for Medicare & Medicaid...

Federal Health Insurance Exchange Weekly Enrollment Snapshot: Week 2: Week 2, Nov 3-9, 2019

In week two of the 2020 Open Enrollment, 754,967 people selected plans using the HealthCare.gov platform. As in past years, enrollment weeks are measured Sunday through Saturday. Consequently, the cumulative totals reported in this snapshot reflect one fewer day than last year.

Every week during Open Enrollment, the Centers for Medicare & Medicaid Services (CMS) will release enrollment snapshots for the HealthCare.gov platform, which is used by the Federally-facilitated Exchange and some State-based Exchanges. These snapshots provide point-in-time estimates of weekly plan selections, call center activity, and visits to HealthCare.gov or CuidadoDeSalud.gov.

The final number of plan selections associated with enrollment activity during a reporting period may change due to plan modifications or cancellations. In addition, the weekly snapshot only reports new plan selections and active plan renewals and does not report the number of consumers who have paid premiums to effectuate their enrollment.

*("Week One" is a misnomer...see highlighted explanation below)

This Just In from the Centers for Medicare & Medicaid...

Federal Health Insurance Exchange Weekly Enrollment Snapshot: Week 1

Week 1, November 1-November 2, 2019

In week one of the 2020 Open Enrollment, 177,082 people selected plans using the HealthCare.gov platform. As in past years, enrollment weeks are measured Sunday through Saturday. Consequently, week one was only two days long this year - from Friday to Saturday.

Every week during Open Enrollment, the Centers for Medicare & Medicaid Services (CMS) will release enrollment snapshots for the HealthCare.gov platform, which is used by the Federally-facilitated Exchange and some State-based Exchanges. These snapshots provide point-in-time estimates of weekly plan selections, call center activity, and visits to HealthCare.gov or CuidadoDeSalud.gov.

It's been pretty obvious for the past two years that the states which fully control their own ACA exchanges (including their own marketing and outreach budgets and their own exchange website platform) seem to be outperforming the states hosted by the federal exchange, HealthCare.Gov, in terms of open enrollment numbers year after year.

However, this can be a bit tricky to compare because some of the states have shifted back and forth...four states which ran their own platform for the first one to three years (Hawaii, Kentucky, Nevada and Oregon) moved home to the mothership in later years, while one state (Idaho) did the reverse--they stuck with HC.gov for 2014 but then broke off onto their own platform after that.

In the Weeks 8/9 Snapshot Report, HHS reported exactly 8,762,355 QHP selections as of New Year's Eve via HealthCare.Gov specifically (which only includes 39 states).

Then, last week, the ASPE department released their "Mid-Season Report", which included more detailed enrollment data for every state...but cut off a week earlier (only through Christmas Eve). After filling in all the blanks, I concluded:

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