Unfortunately, the actual actuarial filing memos ("Part II Justification") weren't available as of this writing, so I couldn't tell whether there's any COVID-19 impact specifically mentioned or not. Montana is one of the states with the fewest casese of COVID per capita, so I wasn't expecting much, but it would be nice to know.
Today I checked again and it looks like they've not only posted the Actuarial Memos (which don't mention COVID-19 at all, as I expected), but it also looks like Montana is the first state to publish their final/approved 2021 rate changes as well. They also modified the estimated enrollment numbers somewhat. Here's what it looks like now:
Last year, thanks to the Section 1332 Reinsurance waiver allowed for by the ACA, Montana health insurance carriers reduced their premiums for 2020 by 13.1% on average on the individual market, while raising them by 7% on the small group market (which the reinsurance program doesn't impact).
I've only written about Montana State Auditor (which includes acting as the Insurance Commissioner, as far as I can tell) Matt Rosendale a couple of times before. The first was in October/November 2017, when he pulled a cynical, disingenuous dick move by deliberately framing a non-profit insurance carrier into losing money for purely political reasons:
Montana commissioner chides insurance companies for raising rates, despite earlier offers to help
BOZEMAN — Montana's insurance commissioner chided two companies for raising rates on health insurance policies offered under the Affordable Care Act after federal subsidies ended, despite earlier telling them they could modify their rates if circumstances changed, the Bozeman Daily Chronicle reported.
...Matt Rosendale said he was "extremely disheartened" that PacificSource and the Co-op increased their premiums, adding that he had been assured by the companies that with or without the cost-sharing reduction payments they would be able to honor the rates they first submitted.
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:
REINSURANCE LOWERS HEALTH INSURANCE RATES FOR 2020
New Program Championed by Rosendale Leads to Double-Digit Rate Decreases in the Individual Market
HELENA, Mont. – State Auditor Matt Rosendale announced today that every health insurance plan sold on the individual market in Montana will have lower rates next year, largely due a new program that he’s championed for the past two years.
Insurance companies offering individual and small group health insurance plans are required to file proposed rates with the Montana State Auditor’s Department of Insurance for review and before plans can be sold to consumers.
What is rate review?
The rate review process, established by the Montana Legislature in 2013, does not give the Commissioner the authority to disapprove rates or prevent them from taking affect. It does give the commissioner the chance to review the factors insurance companies use in setting rates.
If the commissioner finds a rate increase to be excessive or unjustified, the insurer can voluntarily lower the rate increase. If the insurer decides to use the rate anyway, the commissioner will issue a public finding announcing that the rate is unjustified.
HELENA — Gov. Steve Bullock has signed legislation meant to lower premiums for Montana customers who receive health insurance through the Affordable Care Act’s individual marketplace.
Bullock signed the bill Tuesday creating a reinsurance program to help reimburse insurers for high-cost claims so those costs aren’t included in determining individual marketplace premiums for the following year.
U.S. health officials also must approve the plan, which is estimated to offset 2020 premium increases by 10% to 20%.
I just realized that while I've written quite a bit about the potential loss of Medicaid coverage for thousands of residents of Michigan, Kentucky and Arkansas over the past few months due to the new work requirement laws in those states, It's been far too long since I've given a shout-out to the four states which are hoping to add Medicaid expansion (or at least continue it, in one case) exactly one week from today.
For years, elected leaders in conservative states have resisted expanding Medicaid, the government health program for low-income Americans. Now voters in four of those states will decide the question directly.
*(OK, that's hyperbole...unsubsidized enrollees are still left holding the bag for thousands of dollars in unnecessary premium payments for at least another year or so, and there's still no guarantee of the final ruling...see below...)
Almost exactly a year ago, Donald Trump, after 9 months of bluster about doing so so, finally pulled the trigger on his threat to cut off Cost Sharing Reduction reimbursement payments to insurance carriers for the deductibles, co-pays and other out-of-pocket expenses which they agree to cover every month for around 7 million low-income ACA exchange policy enrollees.
Trumps stated goal in doing so was, of course, to "blow up" the ACA, to cause it to "implode" (which is actually the opposite of blowing something up, but that's a different discussion) and ultimately fail in the process.
The state is exploring whether a Montana-run reinsurance program would help lower the premiums people pay when buying their health insurance on the federal marketplace, in some cases by 10-20 percent.
Yes. Yes, it would.
...Montana Gov. Steve Bullock and Department of Administration Director John Lewis are creating a 13-person working group to explore how a state-run reinsurance program might work in Montana. The group will use information from a recent study commissioned by the Montana Healthcare Foundation looking at what reinsurance could mean for the state.
The study shows reinsurance could lower premiums that have risen by double digits in recent years. Those rates could drop anywhere from 9.6 percent to nearly 30 percent on extreme ends of the spectrum, according to the study.
I posted Montana's preliminary/requested 2019 ACA indiividual market rate change requests back in late June. At the time, they were seeking average rate increases of 6.0% statewide, and I estimated that the GOP's repeal of the ACA's individual mandate penalty, combined with the Trump Administration's expansion of #ShortAssPlans, accounted for about 9.9 percentage points of that.
More recently, the state insurance commissioner's website published approved 2019 rate changes. The average increases have been sliced down slightly (from 6.0% to 5.7% on average), and I've lowered my estimate of #ACASabotage impact from 9.9% to 6% based on the lack of either factor being prominently mentioned in the actual carrier rate filings. If accurate that means rates would have been flat year over year on average in 2019 if not for those factors.
Unsubsidized Montana enrollees are paying an average of $637/month this year, so that's roughly a $38/month difference, or around $460 for the full year.
Montana insurer wins lawsuit against feds over unpaid cost-sharing reduction payments
Several health insurers have sued the U.S. government over its failure to make cost-sharing reduction payments that help lower healthcare costs for certain consumers. One just scored the first victory. The U.S. Court of Federal Claims ruled in favor of Montana Health Co-op, which sued the federal government for $5.3 million in unpaid cost-sharing reduction payments, finding that the government violated its obligation under the Affordable Care Act when it stopped paying the CSRs in October 2017."
The rest of the article is behind a paywall, but the gist of it is as follows:
This article from KTVQ is excellent for my purposes. It clearly and cleanly plugs in just about all of the hard numbers I need to run my rate hike analysis: Which carriers are participating in the 2019 ACA individual market; how many current enrollees each carrier has (both on and off the exchange); and the exact average increase each one is requesting for next year!
Health insurers selling individual policies on the “Obamacare” marketplace in Montana are proposing only modest increases for 2019, on average – or, no increase at all.
State Insurance Commissioner Matt Rosendale released the proposed rates Thursday, with Blue Cross and Blue Shield of Montana proposing an average increase of zero – and a 4.9 percent decline for small-group policies.
The other two companies selling policies on the online marketplace, PacificSource and the Montana Health Co-op, proposed average increases of 6.2 percent and 10.6 percent for individual policies, respectively, and lesser increases for small-group policies.