North Dakota

NOTE: This is an updated version of a post from a couple of months ago. Since then, there's been a MASSIVELY important development: The passage of the American Rescue Plan, which includes a dramatic upgrade in ACA subsidies for not only the millions of people already receiving them, but for millions more who didn't previously qualify for financial assistance.

Much has been written by myself and others (especially the Kaiser Family Foundation) about the fact that millions of uninsured Americans are eligible for ZERO PREMIUM Bronze ACA healthcare policies.

I say "Zero Premium" instead of "Free" because there's still deductibles and co-pays involved, although all ACA plans also include a long list of free preventative services from physicals and blood screenings to mammograms and immunizations with no deductible or co-pay involved.

Much has been written by myself and others (especially the Kaiser Family Foundation) about the fact that millions of uninsured Americans are eligible for ZERO PREMIUM Bronze ACA healthcare policies.

I say "Zero Premium" instead of "Free" because there's still deductibles and co-pays involved, although all ACA plans also include a long list of free preventative services from physicals and blood screenings to mammograms and immunizations with no deductible or co-pay involved.

If you have a fairly healthy year, you really could go the entire year without paying a dime in healthcare costs while still taking advantage of many of these free services, and also having the peace of mind that in a worst-case scenario, at least you wouldn't go bankrupt. Not perfect, but a lot better than going bare especially since you wouldn't pay a dime in premiums.

A couple of weeks ago I posted North Dakota's preliminary 2021 individual & small group policy premium rate filings, which averaged a 7.4% increase on the individual market and a 4.1% unweighted average increase for the small group market.

A few days ago, the North Dakota Insurance Dept. posted the final/approved rate hikes, including several significant reductions over those requested:

BISMARCK, N.D. – Insurance Commissioner Jon Godfread today released the approved health insurance rates for both individual and small group plans for 2021, and encourages consumers to start early, stay informed and shop around.

Here's North Dakota's 2021 individual & small group market rate change filings. Note that all of the small group filings are heavily redacted and the memos aren't available in the SERFF database for any of them, so I can't run a weighted average and had to go with the unweighted 5.0% increase.

For the individual market, Blue Cross Blue Shield's memo isn't available, so I had to plug in an estimate based on the average 2019 enrollment; I'm assuming it's fairly close to that this year as well. Weighted average on the indy market is a 7.4% increase.

Last month I noted that North Dakota had posted their requested 2020 premium rate change requests, including two different filings: One assuming the states' ACA Section 1332 Reinsurance Waiver didn't get approved, the other assuming it did. It was pretty unlikely that their waiver would be denied, however, so the general assumption was that they'd be looking at a significant rate reduction, especially compared with the rate increase if the waiver didn't go through.

At the time, I didn't have access to the actual enrollment figures for the three carriers on North Dakota's individual market, so I had to go with an unweighted average rate change, and came up with a drop of 7.9%.

Since then, however, the state regulators have reviewed and approved the 2020 premium changes, and thanks to Louise Norris, I don't even have to dig up the enrollment data:

Average rates dropping by nearly 6% in 2020 (without reinsurance, they’d have increased by nearly 15%)

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

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:

Unfortunately, North Dakota is another state where the carriers have redacted their rate filings. I was able to garner some info about one of the three carriers participating in the Individual Market next year: Medica's filing redaction wasn't done properly, so I was able to extract that they're looking at medical trend of 7.7%, a morbidity reduction of 1.5%, a 2.3% increase due to the reinstatement of the ACA's insurer fee...and a 20% reduction due to the implementation of the state's reinsurance program, which I first reported on last fall and followed up with this spring.

Sure enough, a week or so ago it was made official:

Last September I noted that North Dakota was considering going one of two ways when it comes to making a major change in their individual insurance market: EIther joining over a half-dozen other states in pushing for a reinsurance program (which I strongly support doing), or going the other way and starting to offer weaker policies without some ACA protections the way states like Idaho, Tennessee, Iowa and Kansas either already do or are in the process of doing.

Fortunately, it looks like they ultimately decided to go the former route after all:

A few minutes ago I posted about North Dakota's approved 2019 rate hikes, which are coming in at a mere 3.2% on average (but which would likely be dropping nearly 20 points without both last and this year's #ACASabotage factors).

However, there was something else equally interesting included in the ND DOI press release: Like Montana and several other states, North Dakota is also considering jumping onboard the state-based reinsurance waiver train!

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.

North Dakota was one of only two states (the other one was Vermont) which didn't allow their insurance carriers to add any additional premium load into their 2018 rates to account for Donald Trump's cut-off of Cost Sharing Reduction (CSR) reimbursement payments.

In direct response to this, Medica Health Plans dropped out of the ND on-exchange individual market this year to avoid taking the CSR hit. They hung around the off-exchange market, however, and therefore still have about 600 enrollees in the state.

As a result of this, my estimated impact of ACA sabotage efforts by the Trump Administration and Congressional Republicans has to include the factors from both 2017 and 2018: Cost-Sharing Reduction cut-off (9%) as well as Mandate Repeal and Short-Term Plan expansion (13.8%).

I had actually already written about Vermont doing this back in March, but seeing how it was one of only 2 states (+DC) which didn't allow Cost Sharing Reduction (CSR) costs to be loaded onto premiums at all this year, I figured I should mention it here as well. Once again:

  • 20 states went the full #SilverSwitcharoo route (the best option, since it maximizes tax credits for those eligible for them while minimizing the number of unsubsidized enrollees who get hit with the extra CSR load);
  • 16 states went with partial #SilverLoading (the second best option: Subsidized enrollees get bonus assistance, though not as much as in Switch states; more unsubsidized enrollees take the hit, but they aren't hit quite as hard);
  • 6 states went with "Broad Loading", the worst option because everyone gets hit with at least part of the CSR load except for subsidized Silver enrollees;
  • 6 states took a "Mixed" strategy...which is to say, no particular strategy whatsover. The state insurance dept. left it up to each carrier to decide how to handle the CSR issue, and ended up with a hodge podge of the other three
  • 3 states (well, 2 states + DC, anyway) didn't allow CSR costs to be loaded at all. Their carriers have to eat the loss, which makes little sense, but what're ya gonna do?

Press release from the North Dakota Insurance Dept,, September 28, 2017:

Medica Leaving North Dakota Individual Health Insurance Exchange in 2018
Post date: Sep 28, 2017

BISMARCK, N.D. – Insurance Commissioner Jon Godfread today confirmed that the Insurance Department was informed late Wednesday, Sept. 27, that Medica does not intend to sign an agreement with the federal government to offer coverage on the Affordable Care Act (ACA) Exchange for their individual health insurance in North Dakota for 2018.

“We have had numerous conversations with Medica over the course of the past few months, and given the uncertainty that currently exists around cost sharing reductions, they are unable to move forward in the Federal Exchange,” Godfread said.

In August I wrote that the situation in North Dakota was pretty straightforward: Three carriers on the individual exchange (BCBS, Medica and Sanford), requesting average rate hikes of around 24%, 19% and 12% respectively for an average increase of 23% assuming CSR payments are made, or a bit higher (28%) if they aren't.

Yesterday, however, with the final contract signing deadline having passed on the 27th, Louise Norris reports that one of the three carriers, Medica, was forced to drop out of the market at the last moment...not because they wanted to, but because the ND insurance dept. insisted on carriers pricing 2018 premiums on the assumption CSRs will be paid for the full year.

Medica understandably refused to take that risk (the odds of CSRs being guaranteed are virtually nil, and the odds of them being paid each and every month, as they're supposed to, is only so-so), so they dropped out instead.

North Dakota's numbers are pretty straightforward. Only three carriers, none of whch say anything about CSR or mandate concerns, so I have to assume that their requested rate increases are the best-case scenario. In addition, the KFF estimates suggest only a 5 point additional CSR factor anyway. This results in roughly a 23% average hike if CSRs are paid vs. a 28% increase if they aren't.

Of the 31 states which have expanded Medicaid under the Affordable Care Act, only a handful issue regular monthly or weekly enrollment reports.

I noted in February that enrollment in the ACA's Medicaid expansion program had increased by around 35,000 people across just 4 states (LA, MI, MN & PA).

It's early June now, so I checked in once more, and the numbers have continued to grow. I have the direct links for 5 states now (including New Hampshire)...

Normally I post screenshots from the revised/updated SERFF filings and/or updates at RateReview.HealthCare.Gov, but it takes forever and I think I've more than established my credibility on this sort of thing, so forgive me for not doing so here. Besides, #OE4 is approaching so rapidly now that this entire project will become moot soon enough, as people start actually shopping around and finding out just what their premium changes will be for 2017.

The other reason I'm not too concerned about documenting the latest batch of updates/additional data is because in the end none of it is making much of a difference to the larger national average anyway; no matter how the individual carrier rates jump around in various states, the overall, national weighted average still seems to hover right around the 25% level.

Still, for the record, here's the latest...in four states (Iowa, Indiana, Maine & Tennessee) I've just updated the requested and/or approved average increases. In the other four (Massachusetts, Montana, North & South Dakota) I've added the approved rate hikes as well.

North Dakota's total individual market was 49,000 people in 2014. Assuming a 25% increase since then, it should be roughly 61,000 today, some portion of which is composed of transitional/grandfathered enrollees. I'm going to assume (based on hard numbers from a few other states) that GF/TR enrollees make up perhaps 10% of the total, or 6,100. They enrolled 21,604 people in exchange plans this year, of whom 20,536 were still enrolled as of the end of March. Last year, Blue Cross Blue Shield of ND held roughly 29,000 enrollees total, with Medica making up another 4,800 or so.

All of the above numbers are important when attempting to estimate the weighted average rate hikes requested by ND carriers, because of the 3 operating on the individual market (BCBS, Medica and Sanford), only one of them, Medica, has provided their actual 2016 enrollment tally (7,329).

As I just noted re. South Carolina, Louise Norris has picked up the ball on my "weighted average rate hike" project and seems to be filling in some of the missing pieces using my own methodology. Here's what she comes up with for North Dakota:

Rates for 2016 won’t be finalized until late summer or early fall, but of the three carriers that participated in the exchange in 2015, two – Blue Cross Blue Shield of North Dakota and Medica Health Plans – have requested double digit rate increases for 2016. BCBS of ND has proposed an average rate increase of 18.4 percent for their 29,000 individual market policy-holders (including on and off exchange plans) BCBS of ND has 70 percent of the on-exchange market share in 2015.

Medica has proposed an average rate increase of 16.5 percent, for an estimated 4,778 members, including on and off-exchange.

Sanford’s proposed rate increases were less than 10 percent, as they do not appear on Healthcare.gov’s rate review tool.

Thanks to Paul Mullen for this find: A rare update out of North Dakota. Lots of useful data, but kind of frustrating because of the apples/oranges comparisons:

As of July 6, 9,953 North Dakota residents were covered by private insurance plans obtained through the federal marketplace, up from 8,374 reported at the committee’s last meeting May 14, according to Insurance Department figures.

That’s still lower than the 10,597 enrollment figure cited by the Obama administration in April, in part because the state counts only those who have actually paid their first month’s premium. Either way, enrollment fell short of the administration’s projection that 11,000 North Dakotans would enroll in private plans through the marketplace during its first six months.

UPDATE: On the down side, I was off by 4% this time around.

On the up side, I UNDERESTIMATED:

Actual Feb. enrollments: 942,833, for a total of 4,242,325 thru 3/01/14.

Sarah Kliff at Vox just announced that the February HHS report is expected to be released today at around 4:00pm. A few items in anticipation of that:

  • As I've noted several times, I'm projecting the report to total around 902,000 exchange-based private QHP enrollments for the month of February (technically 2/02 - 3/01)
  • If accurate, this would bring the cumulative total of exchange-based private QHP enrollments to 4.202 million (from 10/1/13 - 3/01/14)
  • From the data I have, the average daily enrollment rate in February was almost identical to that of January, which had about 1.146 million QHP enrollments. HOWEVER, the January report included five weeks of data (12/28 - 2/01), while the February report will only include four weeks (2/02 - 3/01). Therefore, even at the same daily average, it'll be about 20% lower no matter what.
  • Don't be surprised if Peter Lee of CoveredCA decides to steal some thunder by announcing that California has enrolled 1,000,000 QHPs all by itself either today or tomorrow. However, that would include the past 10 days, while the HHS number will only run thru 3/01.
  • If you want to get REALLY specific, call it 902,800 and 4,202,292.
  • I've been dead-on target 6 times in a row without hyping up my projections beforehand. This time I am hyping myself up beforehand, so I'll probably be way off...but as long as I've UNDERestimated the tally, I'll be perfectly fine with that...
  • The report will be released in about 5 minutes, but my kid gets home from school in about 10, so it'll be a good 20 minutes before I can really post anything. Feel free to follow Sarah Kliff of Vox in the meantime!

The good news is that North Dakota's Medicaid tally has gone up from 1,700 as of early January to over 4,000 at the beginning of February. The bad news is that due to an oversight on my part, this is actually a drop from what I had entered in that field (a confusingly-worded article in January led me to confuse enrollees with the potential pool, which was considerably higher). Anyway, ND Medicaid stood at 4,071 as of a month ago.

As of Feb. 1, 4,057 people in North Dakota had selected an insurance plan through the marketplace. That’s up from 2,624 who chose a plan in the final three months of 2013. Another 4,071 here have been determined to be eligible for Medicaid or the Children’s Health Insurance Program.

Right after last night's South Dakota update we have their sister state to the North. ND was at just 265 private enrollments as of 11/30, so this represents a four-fold increase as of January 7. I've subtracted 800 from the "unspecified" pool at the bottom of the spreadsheet to compensate.

Meanwhile, their Medicaid expansion has gone from 1,001 up to around 1,700.

As of the first week of January, when coverage started through plans under the Affordable Care Act, 977 members had signed up with Blue Cross Blue Shield of North Dakota, the state’s dominant insurer.

The Sanford Health Plan enrolled 92 in North Dakota through the new marketplace exchange.

By contrast, enrollment in North Dakota under expanded Medicaid eligibility stands at about 1,700 in the first week of January....

In North Dakota, estimates of new Medicaid enrollees under the expanded eligibility have ranged from an increase of 20,000 to 32,000.