Over at KFF (previously the Kaiser Family Foundation), researchers/analysts Jared Ortaliza, Krutika Amin & Cynthia Cox have put together a new analysis of the overall individual (aka non-group) U.S. health insurance market as of early 2023. While ACA exchange-based enrollment is publicly available (for both subsidized & unsubsidized enrollees) and is the primary focus of this website, off-exchange enrollment is always somewhat fuzzier for several reasons:
Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Accident and Health Insurance (CMS-9904-P)
Short-term, limited duration (STLD) health insurance has long been offered to individuals through the non-group market and through associations. The product was designed for people who experience a temporary gap in health coverage.1 Unlike other products that are considered “limited benefit” or “excepted benefit” policies – such as cancer-only policies or hospital indemnity policies that pay a fixed dollar benefit per inpatient stay – short-term policies are generally considered to be “major medical” coverage; however, short-term policies are distinguished from other comprehensive major medical policies because they only provide coverage for a limited term, typically less than 365 days. Short-term policies are also characterized by other significant limitations, including the types of services covered, often with a dollar maximum.
It took me four full months for me to analyse the 2019 ACA rate filings for the first 30 states, but the remaining 20 should come fast & furious starting today, because it looks like they were all finally uploaded to the official RateReview.HealthCare.Gov website earlier this afternoon.
Case in point: Hawaii. There's four carrier listings at RR.HC.gov, but this is misleading; two of them are basically double-listed (Hawaii Medical Service Association separated out their PPOs and HMOs into separate listings, but the filing itself merges both; the same is true of Kaiser Foundation Health Plan, whish has On and Off-Exchange policies listed separately in the database but again merges them into the same filing). In reality, Hawaii only has two carriers on the Individual Market as they have for years.
A few days ago I noted that Maryland Governor Larry Hogan had signed a bipartisan bill into law which creates a $380 million reinsurance fund which should cancel out up to 21% of next year's looming individual market premium hikes.
However, I forgot to mention the other important thing that the same bill does: Evidently it would also head off Donald Trump's attempt to open the floodgates on the type of minimally-regulated "short-term" and "association" plans which would further damage the ACA-compliant individual market risk pool:
(C) THIS SUBTITLE APPLIES TO ANY HEALTH BENEFIT PLAN OFFERED BY AN ASSOCIATION, A PROFESSIONAL EMPLOYEE ORGANIZATION, OR ANY OTHER ENTITY, INCLUDING A PLAN ISSUED UNDER THE LAWS OF ANOTHER STATE, IF THE HEALTH BENEFIT PLAN COVERS ELIGIBLE EMPLOYEES OF ONE OR MORE SMALL EMPLOYERS AND MEETS THE REQUIREMENTS OF SUBSECTION (A) OF THIS SECTION.
