In the middle of a deadly global pandemic which has already killed more than 100,000 Americans and completely disrupted the entire U.S. healthcare system, private insurance carriers still have to go about preparing their annual premium rate change filings for 2021. This is a long, complicated process which begins a good nine months before the new plans and prices are actually enrolled in.
The task of setting 2020 premiums was the first time since the ACA went into effect which was relatively calm for insurance carrier actuaries:
Governor Whitmer Announces Statewide Closure of All K-12 School Buildings; School building closures will last Monday, March 16 through Sunday, April 5
Today, Governor Gretchen Whitmer announced that in order to slow the spread of Novel Coronavirus (COVID-19) in Michigan, she is ordering the closure of all K-12 school buildings, public, private, and boarding, to students starting Monday, March 16 until Sunday, April 5. School buildings are scheduled to reopen on Monday, April 6.
As of tonight, the number of presumptive positive cases of COVID-19 in Michigan is 12.
I noted yesterday that Virginia is the latest state to consider jumping onboard the State-Based Exchange train, joining Nevada, New Mexico, New Jersey, Pennsylvania, Maine and possibly Oregon in making the move. Every time I've mentioned Oregon, however, I've had to put a bit of an asterisk on it because I wasn't quite sure whether or not their shift back to their own full tech platform was still a go or not.
Like Nevada, Oregon did have their own full exchange once upon a time. Back in the first ACA Open Enrollment Period from 2013-2014, both states were among those which ran their own exchange websites. Nevada's was developed by Xerox; Oregon's was developed by Oracle.
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:
Not much of an entry, but still: A month ago, the Oregon Division of Financial Regulation posted the requested 2020 rate changes for the Individual and Small Group health insurance markets: 3.3% on average for the Indy market, 8.7% for the sm. group market.
Today, after reviewing the requests from the insurance carriers, the department has posted their "semi-final" rates. These may still see some additional tweaking before the final, approved rates are locked in, but the odds are that these will be the final rates:
Salem — Oregonians can now see the state’s preliminary rate decisions for 2020 individual and small employer health insurance plans. The Division of Financial Regulation must review and approve any rates before they can be charged to policyholders.
Preliminary rate decisions are for individuals who buy their own coverage rather than getting it through an employer and for small businesses.
Lawmaker proposes Medicaid buy-in and individual mandate for Oregonians
Representative Andrea Salinas, the new Chair of the House Health Care Committee, recently filed a bill that aims to establish a Medicaid buy-in option for Oregon residents. The bill, HB 2009, would also establish a “shared responsibility penalty,” or an individual mandate for Oregonians.
HB 2009 would essentially allow individuals who do not qualify for Medicaid, or for premium tax credits under the Affordable Care Act, to enroll in CCOs by paying premiums to cover their health services.
Salem, OR—Oregon consumers can get a first look at requested rates for 2020 individual and small group health insurance plans.
In the individual market, seven companies submitted rate change requests ranging from an average 3.2 percent decrease to an average 13.5 percent increase, for an average of 3.3 percent. In the small group market, nine companies submitted rate change requests ranging from an average 0.3 percent decrease to an average 13.1 percent increase, for an average of 8.7 percent.See the chart for the full list of rate change requests.
“It’s early in the process, but we are encouraged to see carriers providing more options to Oregonians by expanding into both rural and coastal communities, and the market stabilizing in spite of uncertainty at the federal level,” said Insurance Commissioner Andrew Stolfi. “Now it is time to start our open and thorough review process that allows Oregonians to provide input on the filings that affect them.”
Steps like a mandate for Oregon residents to buy health insurance and relief for exchange customers who earn too much to receive tax credits under the Affordable Care Act could help reverse premium hikes that have shot up amid attempts by the Trump administration to roll back the law, OSPIRG, the Oregon State Public Interest Group, argued in a report released Wednesday.
There are 12 states which operate their own full ACA exchanges, including their own board of directors, marketing budget, bylaws and tech platform for their enrollment website. 34 states have offloaded just about all of that to the federal exchange, HealthCare.Gov.
And then there are five states which are in between: They have their own state-based exchange...but their tech platform is basically piggybacked onto the federal exchange: Arkansas, Kentucky, Nevada, New Mexico and Oregon.
Nevada and Oregon had such major technical problems at launch that they scrapped their sites after the first year and moved to the Mothership. Hawaii also scrapped their exchange site after the second or third year, but they shut down their entirestate-based exchange and moved everything to HC.gov). Nevada announced that they're giving their own full exchange a second shot this November.
However, they also made sure to note that there was still one more round of reviews to go through before final, approved 2019 rate changes were locked in. Yesterday the OR DFR came out with those, making only slight further changes on the individual market (they bumped Kaiser up by 0.2 points while lowering Providence by 1.1 points). Providence has twice as many enrollees as Kaiser, so this resulted in an overall, weighted statewide average rate increase of 7.3%.
The final small group market rates were changed a bit more--Providence's increase was cut in half, while UnitedHealthcare's hike was cut by a couple of points.
*(OK, these are technically only "semi-approved" rates...there could still be some additional tweaks later on after public comment, etc.)
Oregon was the fourth state which I ran a preliminary 2019 rate increase analysis on back in May. At the time, I concluded that insurance carriers were requesting a weighted average increase of 10.5% for ACA-compliant individual market policies next year. I knew that Oregon's state-based Reinsurance program was helping keep that average down to some degree, but I didn't know exactly how much of a factor it was.
I also knew that efforts to sabotage the ACA by Donald Trump and Congressional Republicans would play a major role in increasing 2019 rates: Repeal of the individual mandate is a big factor, along with the unnecessary 1-point increase in the state exchange fee being imposed on Oregon and the other four states which run their own exchange but "piggyback" on HealthCare.Gov's technology platform.
Oregon just became the 4th state to submit their preliminary 2019 ACA individual market rate filings, and while the expected increase is smaller than expected on average (in part due to Oregon's strict control of short-term plans), repeal of the individual mandate by Congressional Republicans and Donald Trump are still responsible for the vast majority of the rate increase.
As of today, there are 12 states which operate their own full ACA exchanges, including their own board of directors, marketing budget, bylaws and tech platform for their enrollment website. 34 states have offloaded just about all of that to the federal exchange, HealthCare.Gov. And then there are five states which are in between: They have their own state-based exchange...but their tech platform is basically piggybacked onto the federal exchange: Arkansas, Kentucky, Nevada, New Mexico and Oregon.
Arkansas and New Mexico always planned on moving off of HC.gov onto their own full exchange platform but never got around to doing so. Kentucky's ("kynect") was working perfectly well from day one, and only made the move to the federal platform after three years because new GOP Governor Matt Bevin decided he didn't like it for whatever reason. New Mexico and Oregon, meanwhile, had such major technical problems at launch that they scrapped their sites after the first year and moved to the Mothership. (As an aside, Hawaii also scrapped their exchange site after the second or third year, but they shut down their entire state-based exchange and moved everything to HC.gov).
A week ago, Vox's Sarah Kliff reported that the Trump Administration was slashing the 2018 Open Enrollment Period advertising budget by 90% and the navigator/outreach grant budget by nearly 40%. As I noted at the time, the potential negative impact of these moves on enrollment numbers this fall--coming on top of the period being slashed in half, the CSR reimbursement and mandate enforcement sabotage efforts of the Trump/Price HHS Dept. and the general confusion and uncertainty being felt by the GOP spending the past 7 months desperately attempting to repeal the ACA altogether could be significant. In states utilizing the federal exchange (HealthCare.Gov), 2017 enrollment was running neck & neck with 2016 right up until the critical final week...which played out under the Trump Administration, which killed off the final ad/marketing blitz.
Result? A 5.3% total enrollment drop (or 4.7% if you don't include Louisiana, which expanded Medicaid halfway through the year) via HC.gov, while the 12 state-based exchanges--which run their own marketing/advertising budgets--saw a 1.8% increase in total enrollment year over year.
As noted in the Virginia and Maryland updates, I've started going through the earlier state rate filings and revising them to include:
Updated/revised carrier rate filings;
Additional market withdrawls and/or expansions;
Corrections to CSR factor impact, etc.
The original versions of each state writeup includes screen shots of the actual filing documents and explainers behind specific requests; I don't have time for that with most of the updates, so I'm bundling several states together. Here's Connecticut, Oregon and Vermont's revisions: