Trumpcare

Things were looking pretty dicey for two of Montana's three insurance carriers participating on the individual market the past few days. One of the three, Blue Cross Blue Shield, saw the writing on the wall regarding Cost Sharing Reductions (CSR) likely being cut off and filed a hefty 23% rate hike request with the state insurance department. The other two, however (PacificSource and the Montana Health Co-Op, one of a handful of ACA-created cooperatives stll around, assumed that the CSR payments would still be around next year and only filed single-digit rate increases.

I'm not going to speculate as to the reasons why they both did so when it was patently obvious that having the CSRs cut off was a distinct possibility, although I seem to recall the CEO of the Montana Co-Op said something about their hands being tied since CSR reimbursement payments are legally required, after all. Basically, it sounds like he was genuinely trying to avoid passing on any more additional costs to their enrollees than they had to.

Pennsylvania is the first state which has released their approved 2018 rate hikes since Donald Trump officially pulled the plug on CSR reimbursement payments last Friday. It's also one of just 16 states which had yet to do by then. Most of the remaining states are small or mid-sized, so plugging Pennsylvania into the 2018 Rate Hike Project leaves just Texas, North Carolina and New Jersey as missing states with more than 8 million residents.

Back in June, the PA Insurance Commissioner was pretty up front and clear about what the major causes of 2018 rate increases on the individual market would be:

Insurance Commissioner Announces Single-Digit Aggregate 2018 Individual and Small Group Market Rate Requests, Confirming Move Toward Stability Unless Congress or the Trump Administration Act to Disrupt Individual Market

Several healthcare wonk colleagues and I have been carefully piecing together the CSR sabotage price loading strategies for every state over the past week or so. This changed from a theoretical exercise to a real one due to Donald Trump officially pulling the plug on Cost Sharing Reimbursement payments effective immediately late Thursday night.

As in most states, the Michigan Dept. of Financial Services, seeing the potential writing on the wall, sent out a memo to all individual market insurance carriers instructing them to submit two different sets of rate filings for 2018: One assuming CSR payments would continue, the other assuming they won't:

Right on top of his potentially devastating executive order this morning (I haven't written up a formal post about it after the fact, but my explainer from a few days ago does a pretty good job of giving the gist), Donald Trump has supposedly finally decided to lower the boom for real on cutting off the legally and contractually mandated Cost Sharing Reduction reimbursement payments to insurance carriers:

President Donald Trump plans to cut off subsidy payments to insurers selling Obamacare coverage in his most aggressive move yet to undermine the health care law, according to two sources.

The subsidies, which are worth an estimated $7 billion this year and are paid out in monthly installments, may stop almost immediately since Congress hasn’t appropriated funding for the program.

 

Joint post by David Anderson, Charles Gaba, Louise Norris and Andrew Sprung

Note: This post is a joint effort with colleagues who have closely tracked the CSR chaos induced by Trump and Republicans in Congress. Dave Anderson is a former health insurance analyst, now a healthcare scholar at Duke, and a blogger at Balloon Juice; Louise Norris is co-owner with her husband Jay of a unique health insurance brokerage for individual market customers, and a top source of marketplace information and analysis at her own blog as well as at healthinsurance.org and elsewhere. Andrew Sprung writes about healthcare policy on his blog, xpostfactoid, as well as at healthinsurance.org and other publications.

In August I reported that the three individual market carriers in West Virginia (CareFirst, Highmark BCBS and Health Plan of the Upper Ohio Valley) were requesting average rate hikes of around 17.8% assuming CSR payments are made or 27.8% assuming they aren't.

Today the approved rate hikes came out for the first two. I don't know the final rate for the third company, but they're off-exchange only and have just 133 enrollees, so that won't move the needle one way or the other regardless:

The West Virginia Insurance Commission approved rate increases for Highmark West Virginia and CareSource Insurance’s services sold in the “Obamacare” exchange.

MetroNews learned Tuesday premiums for Highmark West Virginia will increase by 25.6 percent, while CareSource Insurance will have a 19.6-percent increase in its rate.

The article goes on to falsely conflate the 2017 and 2018 rate increases, however:

I noted back in August that there will only be one insurance carrier offering policies on the Nebraska individual market next year (Medica), with Blue Cross Blue Shield dropping out.

Medica originally requested a 16.9% average rate hike, but that was based on the assumption that CSR funding would be appropriated. However, Louise Norris reports that the final, approved average increase will actually be more like 31% due specifically to the lack of guaranteed CSR reimbursements.

Medica has 35,269 members on their ACA-compliant individual market plans in 2017. But all of the current Aetna enrollees, as well as off-exchange BCBSNE enrollees, will need to switch to Medica plans at the end of 2017, as Medica will be the only insurer offering plans in Nebraska’s individual market for 2018.

 

A week or so ago, there was some confusing news about how Donald Trump may or may not be planning on signing a new healthcare-related executive order. I didn't write about it earlier because at first it sounded like he was talking about a meaningless "sell across state lines" decree...meaningless because the ACA already allows carriers to sell ACA-compliant policies across state lines, as long as the states in question sign onto an interstate compact.

More recently, however, it became clear that the executive order in question is more dangerous than I thought:

I was a bit confused by the initial rate hike request for individual market carriers in Kansas, but it seems I was overthinking it. There will be three carriers offering indy market plans this year: Medica, Blue Cross Blue Shield of Kansas and Ambetter (aka Centene, but operating under the name "Sunflower State" here, which is just annoying).

Ambetter ("Sunflower State") is new to the state, so there's no "rate hikes" to speak of. My confusion was regarding BCBSKS, which is already on the KS exchange but didn't appear to submit any actual "rate change" request last time I checked. Louise Norris has cleared up this mystery:

WARNING: THIS IS LONG AND WONKY BUT IMPORTANT.

The Cost Sharing Reduction (CSR) payment controversy has been sucking up a huge amount of oxygen over the past 9 months. Most of this is due to Donald Trump repeatedly threatening to cut off the monthly reimbursements to insurance carriers since January, but some of the concern was already there before he even took office. Why? Because the whole reason the CSR payments are at risk of being discontinued in the first place is a federal lawsuit filed by John Boehner on behalf of the House Republican Caucus back in 2014.

The case slowly ground it's way through the judicial process mostly under the radar for a couple of years. Law experts like Nicholas Bagley of the University of Michigan took the view that the case actually had some merit to it on the surface, but should still be shot down due to a lack of standing:

This Just In...

Highmark Blue Cross Blue Shield's 2018 Affordable Care Act marketplace prices will rise by 25 percent, less than it had requested.

The insurer had asked the Department of Insurance for a 33.6 percent increase in June, one month after Aetna announced it would pull out of Delaware's marketplace. The withdrawal will end its coverage of 11,854 Delawareans and make Highmark the only insurance provider in the Delaware marketplace. 

...Right now, about 27,000 Delawareans have health insurance through the marketplace. The rate increases will not affect Medicare, Medicaid or coverage by private and government employers. 

...Highmark's rate request was based on the uncertain future of Obamacare, especially whether the federal government would or would not enforce the mandate that makes uninsured people either opt in or pay a tax penalty, or continue to make the cost sharing reduction payments, which helps reduce prices for low-income Americans.

Protect Our Care is a healthcare advocacy coalition created last December to help fight back against the GOP's attempts to repeal, sabotage and otherwise undermine the Affordable Care Act. This morning they released a report which compiled the approved 2018 individual market rate increases across over two dozen states.

Needless to say, they found that the vast majority of the state insurance regulators and/or carriers themselves are pinning a large chunk (and in some cases, nearly all) of the rate hikes for next year specifically on Trump administration sabotage efforts...primarily uncertainty over CSR payment reimbursements and, to a lesser extent, uncertainty over enforcement of the individual mandate penalty.

Protect Our Care is a healthcare advocacy coalition created last December to help fight back against the GOP's attempts to repeal, sabotage and otherwise undermine the Affordable Care Act. This morning they released a report which compiled the approved 2018 individual market rate increases across over two dozen states.

Needless to say, they found that the vast majority of the state insurance regulators and/or carriers themselves are pinning a large chunk (and in some cases, nearly all) of the rate hikes for next year specifically on Trump administration sabotage efforts...primarily uncertainty over CSR payment reimbursements and, to a lesser extent, uncertainty over enforcement of the individual mandate penalty.

Protect Our Care is a healthcare advocacy coalition created last December to help fight back against the GOP's attempts to repeal, sabotage and otherwise undermine the Affordable Care Act. This morning they released a report which compiled the approved 2018 individual market rate increases across over two dozen states.

Needless to say, they found that the vast majority of the state insurance regulators and/or carriers themselves are pinning a large chunk (and in some cases, nearly all) of the rate hikes for next year specifically on Trump administration sabotage efforts...primarily uncertainty over CSR payment reimbursements and, to a lesser extent, uncertainty over enforcement of the individual mandate penalty.

Protect Our Care is a healthcare advocacy coalition created last December to help fight back against the GOP's attempts to repeal, sabotage and otherwise undermine the Affordable Care Act. This morning they released a report which compiled the approved 2018 individual market rate increases across over two dozen states.

Needless to say, they found that the vast majority of the state insurance regulators and/or carriers themselves are pinning a large chunk (and in some cases, nearly all) of the rate hikes for next year specifically on Trump administration sabotage efforts...primarily uncertainty over CSR payment reimbursements and, to a lesser extent, uncertainty over enforcement of the individual mandate penalty.

Protect Our Care is a healthcare advocacy coalition created last December to help fight back against the GOP's attempts to repeal, sabotage and otherwise undermine the Affordable Care Act. This morning they released a report which compiled the approved 2018 individual market rate increases across over two dozen states.

Needless to say, they found that the vast majority of the state insurance regulators and/or carriers themselves are pinning a large chunk (and in some cases, nearly all) of the rate hikes for next year specifically on Trump administration sabotage efforts...primarily uncertainty over CSR payment reimbursements and, to a lesser extent, uncertainty over enforcement of the individual mandate penalty.

Protect Our Care is a healthcare advocacy coalition created last December to help fight back against the GOP's attempts to repeal, sabotage and otherwise undermine the Affordable Care Act. This morning they released a report which compiled the approved 2018 individual market rate increases across over two dozen states.

Needless to say, they found that the vast majority of the state insurance regulators and/or carriers themselves are pinning a large chunk (and in some cases, nearly all) of the rate hikes for next year specifically on Trump administration sabotage efforts...primarily uncertainty over CSR payment reimbursements and, to a lesser extent, uncertainty over enforcement of the individual mandate penalty.

*(OK, six, anyway)

Here's something refreshing: U.S. Senator Angus King (I-ME) giving a floor speech in which he lays out at least a half a dozen different types of deliberate sabotage of the ACA's upcoming 2018 Open Enrollment Period by the Trump Administration to date. Start at 4:30:

On Senate Floor, King Discusses “Sabotage” of the Affordable Care Act
“Why does anyone want to have fewer people with insurance?”

WASHINGTON, D.C. – U.S. Senator Angus King (I-Maine) today spoke on the floor of the U.S. Senate to address threats to the Affordable Care Act’s healthcare marketplace.

“I’m rising today in sadness, but also in some anger because there’s a lot of talk about the Affordable Care Act collapsing,” said Senator King in his speech. “Mr. President, it is not collapsing – it’s being mugged. It’s being stabbed in the back. It’s being sabotaged, deliberately and consciously by the actions of the Administration. And I want to emphasize – this isn’t about ideology, it’s not about politics… this is about people.

Back in July, I had originally estimated the requested rate increases for New Mexico to average roughly 24.2% with partial Trump Administration sabotage or 37.2% with full sabotage (no CSR payments, full mandate enforcement threat). However, figuring out NM's approved rate hikes is proving to be frustrating.

On the one hand, they have a handy database lookup tool right there on the NM Insurance Dept. website, and they even have the actual premium amount listings for every plan from every carrier in every rating area available. Unfortunately, the premium listings don't give a year over year comparison (or an average percent increase), and the database tool seems not to have been fully updated as of this writing, making it kind of useless. I have some info for a couple of the individual carriers but even that's a bit confusing.

To the best of my knowledge, there are only 2 insurance carriers offering ACA-compliant insurance policies in Arizona next year: Blue Cross Blue Shield of AZ and Centene (branded as HealthNet).

Back in early August, BCBSAZ announced that they were asking for a relatively modest 7.2% rate increase next year in the 13 counties (out of 15 total) where they were offering individual plans. They also explicitly stated that if it weren't for their concerns over whether or not the Trump Administration would guarantee reimbursing their CSR expenses, they'd be keeping the 2018 rates flat year over year. Granted, this is after a massive rate increase for 2017, but it was still welcome news, and once again underscored how much damage the Trump sabotage factor is.

In a year when every state's 2018 Open Enrollment situation is messy to say the least, Minnesota's is far more so:

  • Last year they were facing massive rate hikes, especially for unsubsidized enrollees (yeah, I know, I know, don't say it), and came very close to having all of their carriers bail
  • In response, they agreed to let most of them put a maximum enrollment cap on a First Come First Serve, with Blue Plus (BCBSMN) agreeing to take the "overflow".
  • However, the unsubsidized individual market enrollees were royally screwed, so the state legislature and governor slapped together a special, one-time 25% premium rebate specifically for them. The money came directly out of other portions of the state general fund, I believe. MNsure, the state exchange, also added an extra 8-day special enrollment period for these folks to jump in and get in on the rebate.

About a month ago, Colorado was among the first states to release their approved 2018 individual market rate hikes. At the time, the average unsubsidized rate increases assuming CSR payments are guaranteed for all of 2018 averaged around 26.7% statewide.

As for CSR payments not being made, however, the press release accompanying the rate tables was more vague; it stated that they would be "up to" 14 points higher, but didn't clarify whether that would apply to every individual plan or only the Silver policies, which is how most other states appear to be handling it. I assumed the "no-CSR" average would be roughly 32.9% if the load is only dumped on Silver plans, but 40.7% if spread across all metal levels.

More recently, Louise Norris (who lives in Colorado herself) gave me the bad news: That "up to 14 points" is being spread across everything:

The Idaho Insurance Dept. has made things pretty easy for me. While they don't break out the individual market enrollment numbers by insurance carrier, they do provide the statewide, weighted average of those enrollees: 27% approved vs. the 38% average which was requested  requested (assuming no CSR reimbursement payments)

Now that we've passed the 9/27 contract signing deadline for 2018 carrier participation on the ACA exchanges, the state insurance departments are posting their approved final rates pretty quickly. Arkansas has done a fantastic job of clearly laying out not just what the rate changes will be, but is explicitly stating how much of those increases are due to the GOP's refusal to formally appropriate CSR reimbursement payments next year:

Insurance companies offering individual and small group health insurance plans are required to file proposed rates with the Arkansas Insurance Department for review and approval before plans can be sold to consumers.  The Department reviews rates to ensure that the plans are priced appropriately.  Under Arkansas Law (Ark. Code Ann. § 23-79-110),  the Commissioner shall disapprove a rate filing if he/she finds that the rate is not actuarially sound, is excessive, is inadequate, or is unfairly discriminatory.  The Department relies on outside actuarial analysis by a member of the American Academy of Actuaries to help determine whether a rate filing is sound.

Louise Norris has been saving me the trouble of digging up/writing up the approved rates in several states...

Insurance Commissioner approves rates insurers filed for 2018; Cost to cover CSRs has been added to silver plan premiums

On September 20, the Tennessee Department of Insurance and Commerce (TDIC) announced that the state had approved the rates that insurers had filed for 2018. However, the announcement indicated that Cigna’s approved average rate increase was 42.1 percent, which was based on the filing Cigna submitted in June 2017. An updated filing, with an average rate increase of 36.5 percent, was submitted in August, and TDIC confirmed by phone on September 21 that the updated filing was approved. The slightly smaller rate increase is due to Cigna’s decision to terminate some existing plans and replace them with new plans).

The following average rate increases were approved for 2018 individual market coverage:

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.

Back in August, I reported that thanks to their just-approved federal reinsurance program, Alaska (which has only a single individual market carrier with the most expensive premiums in the country) is looking at an impressive 22% average decrease in their indy market premiums next year. However, that was based on the assumption that CSR reimbursement payments would not be made (or at least not guaranteed).

Last week the Alaska Journal of Commerce reported that the final, approved 2018 rates have been released, and Premera Blue Cross Blue Shield will instead be lowering rates even further:

Alaskans buying health insurance on the individual market will see a decrease of 26.5 percent in rates next year, the sole insurer in the state announced Tuesday.

Alaskans had been paying some of the highest premiums in the nation.

Some Guy, September 19th:

More to the point, however: What other significance does not including CSR funding have?

Well, first of all, is it possible that they'll slip CSRs in before the vote? I suppose so, but consider this:

  • The final deadline for the insurance carriers to actually sign their contracts for 2018 is Sept. 27th, just 8 days from now.
  • The end of the 2017 fiscal year (i.e., the deadline for the GOP to try and cram through Graham-Cassidy with only 50 Senate votes) is Sept. 30th.
  • The CBO is "aiming" to provide a "preliminary assessment" of Graham-Cassidy "early next week" which I presume means Monday the 25th or Tuesday the 26th.
  • I assume the other steps (parlimentary ruling, vote-a-rama, etc) would take place on Wednesday the 27th, the same day the contracts have to be signed.
  • Yom Kippur is the evening of the 29th, running through Saturday the 30th. I can't imagine even McConnell would be that much of a dick to schedule the vote then.
  • That leaves Thursday the 28th or Friday the 29th for the actual vote itself.

That's a day or two after the carrier contracts have been signed.

Earlier today, the Georgia Department of Insurance issued this press release:

INSURANCE DEPARTMENT RELEASES PROPOSED RATES FOR 2018 HEALTHCARE EXCHANGE

Atlanta – Insurance Commissioner Ralph Hudgens announced today that his office had submitted proposed 2018 health insurance rates to the Centers for Medicare and Medicaid Services (CMS) for the federally-facilitated Healthcare Exchange for final federal approval.

“Today my office submitted 2018 Obamacare rates to Washington D.C. for approval,” Hudgens said. “In its fifth year, Obamacare has become even more unaffordable for Georgia’s middle class with potential premium increases up to 57.5 percent. I am disappointed by reports that the latest Obamacare repeal has stalled once again and urge Congress to take action to end this failed health insurance experiment.”

Me, 8 days ago:

More to the point, however: What other significance does not including CSR funding have?

...That means that even if there's a last minute change to the bill, at this point, CSR payments are virtually certain not be guaranteed next year.

...I wouldn't be at all surprised to see more 11th-hour drop-outs next week. Donald Trump and the Republican Party's open sabotage of the ACA will likely bear even more fruit.

Today, literally 11 hours before the contract signing deadline:

Anthem leaving Maine ACA marketplace, citing uncertainty

Anthem Blue Cross Blue Shield has withdrawn nearly all of its offerings from Maine’s Affordable Care Act health insurance marketplace, and the insurer is citing market uncertainty and volatility as the reasons.

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