District of Columbia

2019 OPEN ENROLLMENT ENDS (most states)

Time: D H M S

Last week I acquired the DC Health Link enrollment data for the first two weeks of 2019 Open Enrollment. It showed that DC, unlike most of the other state-based exchanges, was lagging behind last year for the first two weeks (although not as much as most of the HC.gov states).

Well, I just received updated data out of DC and the enrollment situation over the following four weeks didn't improve (if anything they dropped off slightly more):

  • Nov. 1 - Dec. 11, 2017: 19,252 QHP selections
  • Nov. 1 - Dec. 11, 2018: 17,825 QHP selections

That's a drop of around 7.4% year over year so far.

As with most other state-based exchanges, the numbers for both years include auto-renewals, which means the vast bulk of 2019 enrollments are likely already baked in. Last year's final tally was 19,289; DC has already reached 92% of that as of 12/11. Keep in mind that DC's Open Enrollment Period does not end on Saturday the 15th; it continues for another 47 days after that, through January 31st.

The numbers are several weeks out of date, but it's better than nothing: Here's the DC Health Link's official 2019 ACA Open Enrollment report through November 13.

Things weren't looking great as of two weeks in: Total enrollments were down 6.8% (1,202 people) year over year as of the same date. We'll have to see whether things have picked up since then.

As with most other state-based exchanges, the numbers for both years include auto-renewals, which means the vast bulk of 2019 enrollments are likely already baked in. Last year's final tally was 19,289; DC had already reached 85% of that as of 11/13.

DC's report also includes all sorts of wonky demographic breakout data, and even closes with currently effectuated numbers for both the individual and small business (SHOP) markets. Remember, DC's SHOP market is unusually high (especially compared to the individual market) because the ACA requires all members of Congress and their staff to enroll using it if they want their 72% FEHB subsidy.

"But the whole point of the doomsday machine is lost if you keep it a secret! Why didn't you tell the world, eh?

--Dr. Strangelove, 1964

No one applauded the New Jersey legislature and Governor Phil Murphy louder than I did when they swiftly passed several laws this past spring which cancelled out much of the Trump Administration's sabotage of the Affordable Care Act. As a reminder, the laws and waivers they put into effect included:

I originally wrote about District of Columbia carrier requested 2019 ACA rate changes back in June. At the time, they were seeking a weighted average increase of around 15.5% across the District.

However, the DC exchange board was also working quickly in an attempt to counter the Trump Administration's #ACASabotage factors, by voting to restrict short-term plans, to lock in DC's Open Enrollment Period at a full 3 months as in years past, and to reinstate the ACA's individual mandate penalty at the local level.

As of early September, all of these things appeared to have been approved by the exchange board and/or the DC Council.

On September 19, the DC Dept. of Insurance, Securities & Banking posted the approved 2019 ACA rate changes, and the average increase for the individual market had been shaved down from 15.5% to 13.0%:

Less than one month ago:

...back in February...the executive board of the DC ACA exchange unanimously voted to reinstate the mandate. It didn't mean all that much at the time, however, because the authority to reinstate it actually belongs to the DC Council.

Well, thanks to Mr. Levitis for the heads up. If you scroll down to Page 138, you can see that the DC Council has indeed done just that:

TITLE V. HEALTH AND HUMAN SERVICES
SUBTITLE A. INDIVIDUAL HEALTH INSURANCE REQUIREMENT

Sec. 5001. Short title.
This subtitle may be cited as the “Health Insurance Requirement Amendment Act of 2018”.

Sec. 5002. Title 47 of the District of Columbia Official Code is amended as follows:
(a) The table of contents is amended by adding a new chapter designation to read as follows:
“51. Individual Taxpayer Health Insurance Responsibility Requirement”.
(b) A new Chapter 51 is added to read as follows:
“CHAPTER 51. INDIVIDUAL TAXPAYER HEALTH INSURANCE RESPONSIBILITY REQUIREMENT.

*(technically Vermont was the third to do so, but theirs doesn't kick into effect until 2020, and they haven't even crystalized exactly what form it would take anyway.)
**(yeah, I know very well that DC isn't actually a state, but it's pretty awkward to put "state and/or territory" in the headline.)

I realize that 110% of the news/media/political attention is on the bombshell announcement that Supreme Court Justice Anthony Kennedy is retiring at the end of July, but there are other things going on as well, so I'll do my best to soldier on...

More big health care action at the state level: yesterday the DC Council passed what would be the nation's third state-level individual mandate, after Mass. and NJ.https://t.co/BmtnDAQvVp

— Jason A. Levitis (@jasonlevitis) June 27, 2018

Several quick tidbits out of the District of Columbia from the DC Health Benefit Exchange Authority May board meeting:

  • Their preliminary 2019 premium rate filings were originally due by May 1st, but this was bumped out until June 1st. Not available publicly yet, however.

I noted a few weeks ago that as many as 9 states are ramping up plans to reinstate one version or another of the ACA's just-repealed Individual Mandate. I concluded:

My only advice is that if they do take the political risk of imposing a mandate penalty, at least make sure it's more stringent than the one which was just repealed--I'd probably recommend making it something like the same cost as the least-expensive Bronze plan available on the exchange after whatever tax credits they'd otherwise have applied.

Well, I don't know about the details, but it looks like the District of Columbia, at least, is full-steam ahead:

DC Health Benefit Exchange Authority Executive Board Recommends Policies to Protect Health Insurance for District Residents
Friday, February 23, 2018

Huh. Deadline extensions were fairly common in the first couple of years of Open Enrollment, but have mostly been phased out more recently. This is a bit unexpected from the DC Health Link:

.@MayorBowser has extended the deadline for individuals & families to enroll in quality affordable health insurance to Monday, February 5th at 11:59 pm. Take advantage of today's extended hours at enrollment centers across the city. Don't delay #GetCoveredDC pic.twitter.com/8R7zq0EzA1

— DC Health Link (@DCHealthLink) January 31, 2018

 

Of all the state-based exchanges, the one in DC has gone the longest without a formal enrollment update; the last one only included data through December 5th, a whopping 5 weeks ago. Fortunately, the DC board of directors held their monthly meeting last night and produced the following update.

As shown, the tally as of 1/8/18 is 21,352 QHP selections, slightly below last year's 21,437 as of the same date. Since DC (along with California and New York) are sticking with the full 3-month Open Enrollment Period, it should provide a good apples-to-apples comparison (and the fact that very few DC enrollees have CSR assistance also means there's a nominal CSR loading impact, either).

The final, official DC ACA exchange tally last year was 21,248, so technically speaking they've already surpassed that figure...but again, it was 21,437 as of 1/8/17, which means there were at least a few hundred people who were dropped off at the tail end due to cancelling or non-payment of their first premium.

I've just been sent a link to the first official update on ACA exchange enrollment in DC. It includes a whole mess of demographic data (click below for full-size version), but the main takeaway is near the top: 18,740 QHP selections as of December 5th (compared against December 8th of last year). With auto-renewals included, this year's tally is about 2% shy vs. last year, but again, those extra 3 days make a bigger difference than you might think, especially as we approach the mid-December deadline.

It's important to remember that DC, along with California and New York, is sticking with the full 3-month Open Enrollment Period this year, so residents will still have another 6 weeks after 12/15 to sign up for coverage starting in either February or March.

Until now, it looked like the District of Columbia was gonna be hit with rate increases of at least 26% or more. However, it looks like the powers that be negotiated a much better deal, especially from CareFirst:

Washington, D.C. – The District of Columbia Department of Insurance, Securities and Banking (DISB) approved health insurance plan rates for the District of Columbia’s health insurance marketplace, DC Health Link, for plan year 2018.

Insurers filed their initial rates with the Department in May. Since then, DISB engaged in its rate review process resulting in two out of the four insurers revising their rates down from their initial filings, one as much as half of what was proposed. The Department also held a public hearing during the rate review process to allow residents to provide input in the rate review process.

The District of Columbia is the 6th state (OK, it's not a state but it's considered one legislatively for purposes of the ACA) to post their initial 2018 rate filings (h/t to Louise Norris for the heads up). For 2017, the weighted average rate increase for the individual market was a mere 7.3%, highly unusual for this year, while the small group market increase was almost non-existent: Just 0.4% overall.

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