Michiganders purchasing health insurance through the federal marketplace will see an average rate increase of 27.6 percent in 2018, the Michigan Department of Insurance and Financial Services announced Friday.
One reason for the big increase: Uncertainty over whether President Trump will continue to fund Cost-Sharing Reduction payments, which subsidize plans for low- and moderate-income households.
Virginia was the very first state whose 2018 rate filings I analyzed, way back in early May. At the time, the initial filings amounted to 9 carriers on the individual market with an average rate increase request of around 30%. At the time I hadn't started distinguishing between "with CSR payments" or "without CSR payments", so I don't really know which scenario that 30% reflected; it was probably a mix of both depending on the carrier. 61,000 Aetna enrollees would have to shop around for a new carrier since they had previously announced they were pulling out of the individual market.
Up at the top of the site is a big yellow button leading directly to the ongoing 2018 Rate Hike project. Let's face it, though: It's an awful lot of updates to scroll through. In addition, now that we're past the (extended) rate filing deadline, I've been able to make a lot of updates over the past few days (shoutout to Louise Norris, who did much of the grunt work on these).
As of today (September 6th), I now have average requested 2018 rate changes for the individual market across all 50 states + DC, and have made updates/corrections to several of these.
More importantly, I also now have approved 2018 rate changes for 6 states. They only represent around 9% of the population, though, so I wouldn't focus very much on the "national average" for the approved states yet; that will jump around a lot as more states are added to the mix, and likely won't start to settle in until at least half the states are included.
Having said that, here's what things look like as of today:
(sigh) Colorado's state insurance division just released their approved 2018 rate increases (busy day!), and the situation appears to be similar to Maine: The average requested rates which I thought already assumed no CSR reimbursements appear to have assumed CSRs would be paid after all:
Division of Insurance approves health insurance premiums for 2018
Commissioner: Measures to stablize market for 2018 must happen by Sept. 30
DENVER (Sept. 6, 2017) – The Colorado Division of Insurance (DOI), part of the Department of Regulatory Agencies (DORA), has approved the individual and small group health insurance plans for 2018. Average premium changes within each market - individual and small group - as well as the average change for each insurance company are listed below.
The state of Maine's insurance regulatory agency has announced the approved 2018 individual market rate hikes for the three carriers operating in the state. Louise Norris beat me to the punch:
Regulators in Maine published rate proposals for the three Maine exchange insurers in June, and finalized the rates in early September. Insurers proposed two sets of rates: one that assumes cost-sharing reduction (CSR) funding will continue, and another that assumes the federal government will not fund CSRs in 2018.
The Maine Bureau of Insurance initially rejected all three insurers’ rate proposals on August 10, and asked them to submit new rates. The revised rate filings were then approved on September 1. These average approved rate increases all assume that CSR funding will continue in 2018:
Vermont was one of the first states I analyzed back in the late spring; obvoiusly a lot has changed since then, so I updated/revised my analysis of their requested rate hikes for 2018 a couple of weeks ago, with requested average increases of 11.9% if CSR payments are made or 21.6% if they aren't.
Yesterday, Louise Norris gave me a heads up that the Vermont regulators have issued their approved rate increases for the two carriers operating on the individual and small group markets in the tiny state. This makes Vermont the 4th state to announce their approved rates for next year, joining Oregon, Maryland and New York.
Nevada is the final state to post their requested rate hikes for 2018 (or at least they're the last one I tracked down, anyway). I've now done at least a rough analysis of all 50 states + DC, and while some of the data is a bit outdated (remember, I started doing this back in late April/early May), most of it should still be fairly close to the present situation...at least in terms of requested rate hikes.
In Nevada, after much concern that a bunch of rural counties wouldn't have any exchange carriers at all, Centene stepped in to cover them. They aren't listed in the table below, but since I believe they're new to the state, that shouldn't matter in terms of rate increases since there's no base rates to compare against anyway.
Did CMS execute a last-minute reversal on navigator program? That's what independent blogger Charles Gaba is reporting, posting what appear to be internal CMS documents that show the agency was poised to essentially renew last year's funding for this year's ACA open enrollment.
One document posted by Gaba indicates that Randy Pate — tapped by the Trump administration to run Medicare's Center for Consumer Information and Insurance Oversight — signed off on $60 million in program funding on Aug. 24. More. However, CMS ultimately funded the program at less than $37 million for the upcoming enrollment, a 41 percent cut from last year.
Utah has also finally released their requested 2018 individual market rate increases. There are six carriers offering individual policies next year, but only 2 of them are participating on the ACA exchange (and the 4 off-exchange carriers hold less than 4% of the total market combined). In fact, two of the off-exchange-only carriers are barely participating at all: BridgeSpan has only 8 enrollees, while "National Foundation" (a "phantom carrier" which also goes by "Freedom Life" in other states) once again supposedly only has a single "enrollee". Molina has a few hundred off-exchange enrollees, but the bulk of their 70,000-person membership are in exchange-based policies, and they're dropping off the exchange next year, so those 70K will have to choose from one of the two remaining exchange carriers: SelectHealth and the University of Utah.
As I noted back in June, there are 3 carrers on the KS individual market this year: Medica, Blue Cross Blue Shield of Kansas Solutions and Blue Cross Blue Shield of Kansas City. Any confusion between the BCBS names was made moot, however, as BCBS of KC announced they were dropping out of the indy market anyway.
That leaves Medica and BCBSKS, both of whom filed plans to stay on the market...but only Medica appears to have actually submitted rate requests, for a mere 7,600 enrollees:
ACA Signups isn't normally known for "big scoop" stories. Yes, I'm often the first one to openly post analysis and/or debunking of information/data/claims which have already been made public, but I'm not usually the first one to actually make the underlying data itself public in the first place.
My 2018 Rate Hike project petered out a few weeks back with the requested rate increases posted for 46 out of 50 states (along with DC). Unfortunately, the last 4 states (Kansas, Missouri, Nevada and Utah) decided to keep their cards close to their chest, delaying any public viewing of even the requested rate increases for awhile longer.
Trump is slashing Obamacare’s advertising budget by 90 percent
The White House will also cut the in-person outreach program by $23 million.
The Trump administration plans to deeply cut Obamacare outreach and advertising, officials announced Thursday.
Trump will reduce Obamacare advertising spending 90 percent, from the $100 million that Obama administration spent last year to $10 million this year. It will also cut the budget for the in-person enrollment program by 39 percent.
Administration officials cited “diminishing returns” from outreach activities. In a phone call with reporters, they said that most Americans already know about the Affordable Care Act.
A Trump administration official said Wednesday that the administration wanted to stabilize health insurance markets, but refused to say if the government would promote enrollment this fall under the Affordable Care Act or pay for the activities of counselors who help people sign up for coverage.
The official also declined to say whether the administration would continue paying subsidies to insurance companies to compensate them for reducing deductibles and other out-of-pocket costs for low-income people. Without the subsidies, insurers say, they would sharply increase premiums.
The administration, the official suggested, will do the minimum necessary to comply with the law, which Mr. Trump has called “an absolute disaster” and threatened to let collapse.
When I last checked in on Maryland's individual market rate hikes for next year, the picture was pretty grim: Overall requested increases of around 46%...and that assumed that CSR reimbursements are made in 2018. If you assume CSRs aren't paid, it looked even worse: A whopping 57% average increase statewide for unsubsidized enrollees. Ouch.
As I noted last month with my "Silver Switcharoo" explainer, for carriers which remain in the ACA exchanges next year, there's three potential scenarios which could happen (well, four, actually, if you include "Congress manages to sneak a full CSR appropriation bill into law just under the wire", although that seems pretty unlikely at this point given the time crunch and the fact that it'd need a 2/3 majority in both the House and Senate to avoid being vetoed by Trump anyway):
Back in early June, the New York Dept. of Financial Services posted the requested 2018 rate hikes for the individual and small group markets. In most states, the CSR reimbursement issue is a much bigger factor than whether or not the Trump Administration enforces the individual mandate, but in New York it's the exact opposite: According to the NY DFS, loss of CSR payments would only tack on 1.3 points to the total, while "a full repeal of the federal individual mandate would increase rates by an additional 32.6%".
The reason for the fairly nominal CSR factor is that the vast majority of NY's CSR-eligible population (those earning 138-200% FPL) is instead enrolled in the state's Basic Health Program. As a result, only 26% of New York's exchange enrollees receive CSR assistance, and the 200-250% FPL recipients only receive a fairly skimpy amount of CSR help anyway. At the opposite end of the spectrum, the 32-point mandate factor is far higher than most carriers are indicating (more like 4-5 points), but there's a big difference between the administration "not enforcing" the penalty and outright repealing it, which NY DFS is talking about.
In any event, this means that NY's requested average increases boiled down to: 15.0% if CSRs are paid/mandate enforced, 16.6% if CSRs aren't paid/mandate is enforced, or a whopping 50.5% if CSRs aren't paid and the mandate was repealed.
As I noted earlier today, there’s a gazillion ways the Trump Administration could sabotage (and in some cases, is already sabotaging) the 2018 Open Enrollment period this fall, doing everything in their power to dampen, obstruct and otherwise minimize the number of people who actually enroll in a healthcare policy via the federal ACA exchanges.
However, as I've noted before (and as the CBO confirmed last week), due to the confusing, inside out way in which the APTC and CSR subsidy formulas happen to work, there's also the potential for one of the most pressing sabotage schemes by Trump and the GOP to backfire completely, leading to the potential for a significant increase in ACA exchange enrollment.
I've noted before that even if the Trump Administration does ensure CSR reimbursement payments and does enforce the individual mandate in 2018, there are literally dozens of other ways that Trump and HHS Secretary Tom Price could sabotage the 2018 Open Enrollment Period. Here's just a few, several of which they've already been caught doing:
Minimal or non-existent advertising/outreach/promotional efforts
Understaffing of call centers/support staff, leading to absurdly long hold times
Deliberately underthrottled server bandwidth, slowing HC.gov down or even taking it offline, especially during peak hours
"Accidentally" misentered enrollment instructions or policy specifications
Confusing or missing confirmation/status notification messages either on the site, via email or both
For all the fuss and bother about how much premiums are expected to go up on a percentage basis next year, using percentages can be misleading, since the lower the premium is to begin with, the more dramatic a percentage increase is going to seem relative to where it started.
As I noted when I debunked/corrected the ASPE report, not only did it turn out to be somewhat lower when all 50 states were included (84%, not 105%), but the ASPE report completely ignores both the financial assistance provided to roughly half the market and, just as importantly, blows off the apples to oranges mismatch between the numbers, because only a handful of states had guaranteed issue laws in 2013, and only one (NY) had a community rating law. Having said that, as long as you keep those caveats in mind, the (corrected) ASPE report does provide a good baseline for figuring out what the 2018 premiums are likely to be.
By merging the spreadsheets for these projects together, I've come up with a rough idea of what I expect to see in terms of unsubsidized, full-price premiums for individual ACA policies this November. I'm using a median instead of a weighted average this time around because I expect high variables in terms of the number of people who enroll in each state compared to 2017 (unfortunately, I still don't have 2018 data for several states, and I don't have the 2017 dollar average for DC to compare against).
I've ordered the states from lowest to highest based on the assumption that CSR reimbursements aren't made next year ("full sabotage effect"). The blue sections are my best estimates for each state assuming CSRs are paid; the yellow sections represent how much of the average premiums are due to "CSR padding" by the carriers.
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:
As noted the other day, now that I've compiled the initial 2018 rate filing requests for 46 states + DC (the remaining 4 states aren't public yet), it's time to go back to the earlier states I analyzed and see whether there's been any updates/corrections to my original estimates. I started running the numbers back in early May, and a lot has changed since then, with carriers dropping out of the exchanges, expanding to fill the gaps or simply refiling with revised pricing requests.
For the past two years, Virginia has been the first state in the nation to post their initial rate filings for the following year. I originally compiled their individual market 2018 change requests back in early May, and came up with the following at the time:
UnitedHealthcare had previously announced they were dropping out of Virginia, but I didn't have an enrollee number for them, and Aetna had also just announced their withdrawl from the state. I hadn't yet finalized my "CSR/Mandate Penalty" factor layout yet; at the time I assumed the 30.6% weighted average requested assumed full CSR/mandate sabotage and reduced that number by 17 points based on the Kaiser Family Foundation's "19% national average CSR rate hike" estimate analysis, which estimated the CSR impact at 17 points for Virginia.
I've completed this process for 46 states + DC. I've confirmed (well, really, Louise Norris confirmed for me) that the filing data for the four missing states--Kansas, Missouri, Nevada and Utah--won't be made available publicly for another couple of weeks, which is irritating...but those four states combined only make up about 5% of the total population anyway; unless their average rate increase requests are significantly higher (or lower) than the average of the rest of the states, they aren't gonna move the needle up or down by more than a tenth of a point or so.
Like Wisconsin and Michigan, Ohio has a high number of carriers statewide...although the per-county competition is still lacking in some areas. Even so, their rate hike requests are still pretty high even with CSR payments being made...and dramatically higher if they aren't.
One interesting tidbit: Check out the CareSource filing letter (first one below the table). They don't mention CSRs or mandate enforcement...but they do specify that a full 5 points of their 23.9% increase request is tied to prescription drug inflation (see Shkreli, Martin)...and even more noteworthy, they say that another 5 points is due specifically to "a number of previously [Medicaid-] qualified individuals" being kicked over to the private exchange,
I had already posted a partial look at the New Jersey rate hike situation a couple of weeks ago with a video in which Topher Spiro of the Center for American Progress interviewed NJ Congressman Frank Pallone about the situation. Since his comments weren't official and only referred to Horizon Blue Cross, I didn't make it an official part of the Rate Hike spreadsheet, but now I've managed to plug in the remaining carriers and here's how it looks. As expected, with Horizon holding a commanding 70% market share, the statewide average is around 8.5% if CSR payments are made and the mandate is enforced versus 21.6% if CSR payments aren't made and the mandate isn't enforced.
Also, check out Horizon's cover letter explaining the rate hike...they're not screwing around with who to pin the blame on.
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.
Last year, Blue Cross Blue Shield of Oklahoma, as the only carrier participating on the ACA exchange in the state, jacked up their premiums by a jaw-dropping 76%. This resulted in the highest statewide average rate hike in the country of 71% overall.
Well, that certainly seems to have done the trick: This year BCBSOK (still the only on-exchange player and holding over 99% of the market anyway) is requesting a (relatively) modest 8.3% average rate increase...and their filing specifically calls out both the CSR and mandate enforcement factors as being major reasons. Assuming the Kaiser Family Foundation's estimates are accurate, that means that if the CSR payments were guaranteed for 2018, BCBSOK should actually be lowering their rates slightly, to the tune of around 2.4%.
Adding in the steep hikes from off-exchange only CommunityCare (which only has 1,400 enrollees) brings the averages in at a 1.9% rate drop if CSRs are paid, and an 8.7% increase if they aren't.