Mandate Repeal

via Covered California:

New Analysis Finds Leading State-Based Marketplaces Have Performed Well, and Highlights the Impact of the Federal Mandate Penalty Removal

  • The report examines the impact that federal and state actions have had on state-based marketplaces and the federally facilitated marketplace (FFM).
  • Cumulative premium increases in California, Massachusetts and Washington are less than half of the increases seen in FFM states, but 2019 premium increases spiked in California and Washington compared to Massachusetts, which continued its state-based penalty.

WASHINGTON D.C. — A new report highlights the benefits of state-based exchanges, particularly in the areas of controlling premium costs and attracting new enrollment. The report, which was produced by Covered California, the Massachusetts Health Connector and the Washington Health Benefit Exchange, found that premiums in these states were less than half of what consumers saw in the 39 states that relied on the federally facilitated marketplace (FFM) between 2014 and 2019.

*"Not as bad as expected" depends on your perspective. Even the 6-7-point average premium increase caused by mandate repeal is still an average of $430 - $500 per unsubsidized enrollee for the year...or $1,300 - $1,500/year for a family of three.

Earlier this year, most healthcare wonks (along with the Congressional Budget Office) projected that Congressional Republicans repealing the ACA's individual mandate last December (effective January 1, 2019) would have a significant Adverse Selection impact on the ACA-compliant individual market risk pool. Projections of the premium increases imposed in response to the drop-off of healthy enrollees ranged from 10% (CBO) to as high as 16.6% (Urban Institute, although that also included a small increase due to Trump's expansion of short-term plans as well).

As I noted a few days ago, now that the 2019 ACA Open Enrollment Period is actually underway and the approved individual market premium rate changes have been posted publicly for every state, I'm finally able to go back and wrap up my 2019 Rate Hike Project for the nine states which I was still missing final numbers for.

As I further noted, the approved rates in most of those states didn't change much compared to the preliminary/requested rate changes I had already analyzed earlier this year:

I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.

Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these.

Nebraska has a slightly confusing siutation, which is surprising since Medica is the only carrier offering ACA policies in the state, When I first took a look at the requested premium changes for 2019 back in August, it looked like the average was around 1.0%...that was based on splitting the difference between the 3.69% and -2.60% listings, since the filing form was redacted and I didn't know what the relative market split was between Medica's product lines.

I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.

Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these.

West Virginia's requested average rate increase was among the highest in the country for 2019--a weighted average of around 14.9%.

However, while state insurance regulators left one of the three carriers offering individual market policies alone, they knocked the other two down substantially: CareSource was lowered from around 13.1% to 9.5%, while Highmark Blue Cross Blue Shield was lowered from an average of 15.9% to 9.0%.

I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.

Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these. In addition, in a few states the insurance department has also posted their own final/approved rate summary.

I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.

Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these. Making things even easier (although not necessarily better from an enrollee perspective), in three states the approved rates are exactly what the requested rates were for every carrier: Alabama, Mississippi and Utah:

This is about as minor a rate filing update as I've had, but I'm posting it separately in the interest of completeness.

Insurance carriers in my home state of Michigan originally submitted their requested 2019 ACA individual market rate filings back in June. At the time, the average premium increase being asked for was pretty nominal, around 1.7%, with a smaller-than-average #ACASabotage factor of around 5% due to the ACA's Individual Mandate being repealed and #ShortAssPlans being expanded by the Trump Administration.

Today, just two days before the 2019 Open Enrollment Period actually begins, the Michigan Dept. of Financial Services finally posted the approved 2019 rate filings...and practically nothing ended up changing.

There was practically no change whatsoever between the rate changes requested by Louisiana carriers for the 2019 ACA individual market and the rates approved by the state insurance regulators. However, it's still good to be able to lock in the official rates just ahead of the Open Enrollment Period itself, including the individual filing data.

Overall, unsubsidized premiums should drop around 6.5%, which is good news...except that, once again, if it weren't for the ACA's individual mandate being repealed and #ShortAssPlans being expanded by the Trump Administration, I estimate they'd be dropping by another 9.3%, give or take, for a total premium reduction of more like 15.8% on average.

At $649/month full-price on average this year, that means the average unsubsidized enrollee will be paying somewhere around $724 more apiece next year due to those factors.

OK, this is a pretty minor update, but in the interest of completeness I should post it.

In mid-September, the Washington State insurance commissioner posted the approved 2019 average ACA individual market premium changes for carriers statewide, coming in at 13.8% overall.

The only problem is that the report only included the seven on-exchange ACA market carriers. The four carriers which offer off-exchange policies (which are pretty much identical and are part of the same risk pool, but don't qualify for tax credits) weren't included. They make up roughly 23% of Washington State's total individual market.

Today, just a few days before Open Enrollment begins, the WA Insurance Commissioner posted the complete approved rate change information. The overall average has dropped slightly, to 13.6%:

Eleven insurers approved to sell 74 plans in Washington's 2019 individual market
13.57 percent average rate increase approved

October 29, 2018

As regular readers know, every spring/summer I spend countless hours poring over the annual insurance carrier rate filings, plugging in increases (and occasionally decreases) in ACA-compliant premium changes for every carrier in every state. I actually do this twice for most states (and occasionally even three times), as the process moves from preliminary/requested rate changes to "semifinal" rates to "final/approved" rates throughout the fall.

For 2018 and again for 2019, I've taken this one step further; instead of simply running the overall weighted average premium changes in each state, I've also attempted to break out what portion of the change is caused by various factors...in particular, what portion is caused by legislative or regulatory changes by Congressional Republicans and/or the Trump Administration.

OK, I had kind of forgotten about this. Back in early June, insurance carriers in Pennsylvania submitted their preliminary 2019 ACA market premium change requests. At the time, they averaged around a 4.9% increase statewide, which seemed pretty impressive under the circumstances.

Then, late July, the PA insurance department issued a press release stating that state regulators had modified the 2019 requests, and that the new, revised average was much lower...a mere 0.7% average rate hike. However, the individual carriers as well as the insurance department made it very clear that this nominal increase included a 6 point rate increase to account for the ACA's individual mandate being repealed and the Trump Administration's expansion of non-ACA compliant short-term and association plans.

I originally wrote about District of Columbia carrier requested 2019 ACA rate changes back in June. At the time, they were seeking a weighted average increase of around 15.5% across the District.

However, the DC exchange board was also working quickly in an attempt to counter the Trump Administration's #ACASabotage factors, by voting to restrict short-term plans, to lock in DC's Open Enrollment Period at a full 3 months as in years past, and to reinstate the ACA's individual mandate penalty at the local level.

As of early September, all of these things appeared to have been approved by the exchange board and/or the DC Council.

On September 19, the DC Dept. of Insurance, Securities & Banking posted the approved 2019 ACA rate changes, and the average increase for the individual market had been shaved down from 15.5% to 13.0%:

I analysed Kansas' 2019 ACA indy market rate changes back in August. The three carriers were requesting an average increase of around 6.1% (this may be slightly off since I had to estimate the market share for two of the three). State insurance regulators left Blue Cross Blue Shield and Ambetter's rate requests as is, but cut Medica's down by more than half, from a 10.7% increase to just 4.3%:

Premium Rates for Individual and Small Group Markets Individual plan premium rates may vary by age, rating area, family composition and tobacco usage. For example, a person living in Manhattan, KS (rating area 3) may pay a different rate than someone living in Pittsburg, KS (rating area 7) based on the claims data by rating area. A map of the counties included in each rating area is provided on the next page. Kansas is an effective rate review state, which means the actuarial review is conducted by the Kansas Insurance Department. KHIIS (Kansas Health Insurance Information System) claims data is utilized during the rate review process to verify the claims experience submitted by the companies. The following table provides details regarding the average requested rate revisions for companies writing individual policies in Kansas. Rate increases will be partially offset for individuals receiving a premium tax credit.

Back in June, Indiana's 3 individual market carriers submitted their requested 2019 ACA rate changes, which averaged around 5.1%. At the time I also pegged the impact of #ACASabotage on 2019 rates (mandate repeal + #ShortAssPlans) at around 13 percentage points.

This week I've found Indiana's approved 2019 rate changes for the individual and small group markets. State regulators cut the overall average increase for the individual market in half, to just 2.6%:

Last month, the Idaho Insurance Department posted the preliminary 2019 ACA individual market rate change requests. They were pretty straightforward, averaging around an 8% increase across the market.

A few days ago, the Idaho DOI issued their final/approved rate changes, knocking a few points off the hikes and bringing the weighted average increase down to 5%:

The Department of Insurance received preliminary 2019 health plan information from insurance carriers on June 1 and began reviewing the proposed plan documents and rates for compliance with Idaho and federal regulations. The Department of Insurance does not have the authority to set or establish insurance rates, but it does have the authority to deem rate increases submitted by insurance companies as reasonable or unreasonable. After the review and negotiation process, the carriers submit their final rate 2019 increase information. The public is invited to provide comments on the rate changes. Please send any comments to Idaho Department of Insurance.

Wisconsin has an interesting situation. On the one hand, the state has what should be a robust, highly-competitive individual insurance market,with over a dozen carriers offering policies throughout the state. Granted, some of them are likely limited to only a handful of counties, but in theory they should be doing pretty well compared to rural states like Oklahoma or Wyoming, which only have a single carrier on the exchange.

On the other hand, last year Wisconsin ahd among the highest average premium rate increases in the country. Rates were projected to increase by an already-awful 36%, but when the dust settled the average unsubsidized ACA enrollee in Wisconsin was paying a whopping 44% more than they did in 2017 (it was around 45.8% higher as of the end of Open Enrollment but later dropped a bit as the year has passed and net attrition has tweaked the enrollment base).

Less than 4 weeks away from the midterms, after a year and a half of doing everything possible to tear it down, the Trump Administration is suddenly thrilled with Obamacare. From HHS Secretary Alex Azar's chutzpah-filled Op-Ed in the Washington Post a few weeks back to Donald Trump's 870 word pile of steaming bullshit in USA Today this week, the Trumpsters are now gaslighting to a breathtaking degree.

The latest volley in their attempt to gaslight the country on healthcare is this morning's press release from CMS about 2019 ACA premiums. Let's take a look:

I ran the numbers for Illinois' requested 2019 ACA individual market rate changes back in August. At the time, the weighted year-over-year average was a mere 0.7% increase, with Cigna and Health Alliance's 10% and 7.5% being mostly cancelled out by Celtic's 1.1% and especially Blue Cross Blue Shield's slight drop of 0.9%. Since BCBSIL holds something like 3/4 of the state's individual market share, that alone mostly wiped out the other increases.

Unfortunately, I don't have access to the hard enrollment numbers, so this was a rough estimate based on 2017's breakout. Here's what it looked like at the time:

Yesterday, the Illinois Department of Insurance issued a press release with the final/approved 2019 ACA premium changes, but it's a bit vague about the hard numbers:

The Arizona insurance department posted their final, approved 2019 premium rate changes last week. There's only slight changes to the preliminary/requested rate changes from back in August, which averaged around a 5.3% rate reduction overall.

The final unsubsidized rates are down about one point more, down 6.3% from 2018 rates. However, as all three current carriers clearly noted in August, the repeal of the ACA's individual mandate and expansion of short-term and association health plans (aka #ShortAssPlans) still caused a significant premium increase, which means without those factors, 2019 rates would likely be down significantly more...likely nearly 20% instead of 6.3%:

With the 2019 Open Enrollment Period quickly approaching, I'm spending a lot of time swapping out the requested carrier rate changes from earlier this summer with the approved rate changes from state regulators.

Hawaii only has two carriers participating in the ACA-compliant individual market: HMSA and Kaiser, which requested rate increases of 2.72% and 28.6% respectively back in August. With a roughly 57/42 market share split, this resulted in a weighted average rate increase of 13.8%, which would likely have been closer to 3.8% if the ACA's individual mandate penalty hadn't been repealed.

Today, however, Louise Norris gave me a heads up to this bulletin from Hawaii's Commerce Department, in which they state that state regulators have chopped those rate hikes down significantly for 2019:

HAWAII 2019 AFFORDABLE CARE ACT INDIVIDUAL RATES

With just 3 weeks to go before the 2019 Open Enrollment Period begins, the dust has mostly settled on my 2019 Rate Hike Project. Over half the states have provided their final, approved individual market premium changes, and while I haven't found the final rates for the other half yet, their preliminary rates are all on record, so I don't anticipate the needle moving too much at this point.

New Hampshire is among the states which I haven't found final rate changes for yet. The three carriers in the state have requested average price reductions of around 13.5% on average, which is well below the 3.2% increase which is the average nationally, but I still don't know what the state regulators are going to approve.

This makes the following press release rather surprising:

NH Insurance Department to Hold Oct. 30 Annual Public Hearing on Health Insurance Premiums

When I last posted about 2019 ACA-compliant individual market premium changes in Tennessee back in August, I noted that premiums statewide had gone from dropping 5.7% to dropping 10.8% on average after the Trump Administration first stated that they were going to unnecessarily "freeze" the ACA's Risk Adjustment fund transfers in response to a lawsuit ruling only to reverse themselves a week or so later and state that they were going to go ahead and process RA fund transfers after all.

In other words, the Trump Administration once again deliberately caused a panic across the industry only to "save" the industry from the very threat which they had posed in the first place.

In any event, here's what I thought the Tennessee's premium situation looked like when the dust settled:

Back in August, Blue Cross Blue Shield of South Carolina, the only carrier offering policies on SC's individual insurance market, asked for a 9.2% average premium rate increase for 2019 statewide. This consisted of 9.3% for their most popular plans (which cover over 200,000 South Carolinans) and 6.9% for 6,800 BlueChoice plan enrollees (BlueChoice is only available off-exchange).

Today the South Carolina Insurance Department posted the approved rate changes for 2019, and in addition to shaving several points off of each BCBSSC division, they also announced a new entrant to the SC market (although only in Charleston County):

2019 PRELIMINARY HEALTH INSURANCE PLANS RATE CHANGES FOR INDIVIDUAL MARKET COVERAGE

The SCDOI has approved the rates and forms for health insurance issuers that are planning to offer ACAcompliant products in the individual market in 2019.

This Just In from Connect for Health Colorado:

Most Connect for Health Colorado® Customers Will See Decrease in Premiums for 2019 as Marketplace Stabilizes

DENVER — With rate increases lower than the state has seen in years, Connect for Health Colorado® customers who qualify for financial help are looking at an average decrease in their net (after tax credit) premium of 24 percent next year.

The Colorado Division of Insurance today issued final approval for individual health insurance plans that will increase by an average of 5.6% in 2019. The relatively small increase in monthly premiums and the return of all seven health insurance companies to the Connect for Health Colorado, the state’s health insurance Marketplace, are signs of a stabilizing market for Coloradans who buy their own health insurance coverage.

Minnesota, currently entering their second year of their official reinsurance waiver program to help keep unsubsidized premiums down, announced their preliminary 2019 rate hikes way back in June. At the time, the carriers were looking at roughly an 8% average reduction in rates next year...although they would be dropping prices by more like 15% if not for the ACA's individual mandate being repealed and the expansion of #ShortAssPlans.

Today the Minnesota Dept. of Commerce posted the approved 2019 premium changes, and there's been some dramatic reductionsfor three of the five carriers offering policies in the state. Group Health and Medica were approved as is, but Blue Plus was told to drop their rates a whopping 27.7% instead of the 11.8% they were planning on. Ucare was shaved down from a 7 point reduction to 10 points, and PreferredOne (which only sells individual market policies off-exchange and only has 300 enrollees anyway) was knocked down from a 3-point reduction to 11 points.

I ran the numbers for Nevada's preliminary 2019 ACA individual market rate changes back in July. At the time, the average requested rate increase was around 2.3% statewide.

With the 2019 Open Enrollment Period coming up fast, I checked on the approved rate changes and found that state regulators had cut down on the rates quite a bit...although mostly for carriers which only offer off-exchange plans and only have small numbers of enrollees anyway.

For instance, HMO Colorado (dba HMO Nevada) originally requested a 20.9% increase; this was reduced to 9.5%...but they only have 200 people enrolled anyway, so it's not even a rounding error. Rocky Mountain was cut from 34.4% to 18.5%...but only has 300 enrollees, and so on.

The three carriers which hold the vast bulk of the market had far less dramatic changes, although Silver Summit was cut from a 5.2% increase to a 1.1% decrease for 2019.

Today at 11am CST (I think that's Noon EST?), HHS Secretary and Donald Trump's Used Car Salesman Alex Azar will give a Big Speech to the Nashville Health Care Council in Tennessee:

Tomorrow, HHS Secretary Azar will join Governor Haslam in Nashville, Tennessee to deliver remarks at an event hosted by the Nashville Health Care Council.

Secretary Azar will share news regarding the Affordable Care Act marketplace and reflect on lessons for healthcare reform.

In advance of tomorrow, here are a few excerpts of Secretary Azar’s remarks (as prepared for delivery):

“The previous administration’s major healthcare achievement, the Affordable Care Act, was an attempt to use more government regulation and intervention to improve American healthcare.

“As we all know, the results were disastrous, with skyrocketing costs and disappearing choices.

“But today, I am here to share with you some good news.

As I noted last month when I first analyzed the requested 2019 rates for North Dakota insurers, ND was somewhat unique last year in that it was one of only two states (the other was Vermont) which didn't tack on any extra premium increases for 2018 to account for the lost Cost Sharing Reduction reimbursement revenue after Donald Trump cut off those payments last October.

This led to one of North Dakota's three carriers, Medica, dropping off the ACA exchange altogether, though they still ended up enrolling a few hundred people directly via the off-exchange market.

This is a pretty minor update, but I'm trying to lock in all of the approved 2019 rate changes as they come in. Last month, South Dakota's two carriers, Avera and Sanford, posted requested rate increases which I thought were 2.6% and 10.0% at the time. I also estimated their relative enrollment at around 27,000 and 4,000 enrollees apiece for market share calculations, which gave a statewide average increase of around 3.5%.

I checked the South Dakota Insurance Division website again today, and it certainly looks like the filings have been approved by the state insurance regulators...however, when I double-checked the filings themselves, it looks like they were actually slightly lower than I thought: 2.5% and 9.7% respectively.

In addition, I was able to find the hard enrollment numbers for each...the total is pretty close to what I had it at (29,180 vs. 31,000), but the splut is quite different. Insetad of Avera still having an 87% market share, it looks ike the split is more like 63/37 this year. Since Sanford is requesting a significantly higher increase than Avera, that means the weighted statewide average is higher as well...around 5.2% instead of 3.5%.

Pages