Mandate Repeal

2018 MIDTERM ELECTION

Time: D H M S

Illinois has the same four ACA indy market carriers participating next year as they do this year. All four rate filings specificlaly call out Mandate Repeal and #ShortAssPlans as significant factors in their rate requests, but none of them break out the actual amount, so I'm relying on my standard assumption of 2/3 of the Urban Institute's projections.

In Illinois' case, that's 2/3 of 19.4%, or around a 12.9% #ACASabotage premium increase for unsubsidized enrollees.

I should also note that only one of the four carriers (Health Alliance) specifies just how many enrollees they have; for the other three I'm basing my estimates on last year's numbers for now. The two carriers with what I assume are still the largest market share (BCBS and Celtic) are basically keeping rates flat year over year, while the other two are 7.5% and 10% apiece, for an average rate increase of just 0.7% statewide.

Unsubsidized Illinois residents are currently paying $644/month on average, so a 12.9% sabotage effect means that each of them will have to pay nearly $1,000 extra next year. Ouch.

As you may recall, the New York carriers had originally requested an average 2019 rate increase of 24%...fully half of which they pegged specifically on the ACA's individual mandate being repealed by Congressional Republicans.

On Monday afternoon, there was a rather surreal and surprising announcement made by New York Governor Andrew Cuomo:

Gov. Cuomo just announced that he has directed Supt. Vullo to reject any individual market rate increase that included an increase to compensate for the repeal of the individual mandate

...Assuming that nothing else changes during the rate review process, this makes carriers that didn't associate a % of their rate request with the loss of the mandate big winners...and those who did, not so much.

I noted at the time that while this may seem insane on the face of it, there may be a simple explanation:

Idaho's insurance department website displays their annual rate filing summaries in a unique way--they don't publish the actual enrollment numbers, but they do post breakouts of the rate hikes for different metal levels (handy!) as well as the premiums brought in and claims paid out, which gives some refreshing insight into just how profitable (or not) some fo the carriers are (if I'm reading the screenshot correctly, it looks to me like BCBS and Mountain Health did just fine last year, but the other three carriers ended up in the hole (especially SelectHealth...ouch).

The state website also claims the overall weighted averge rate increase being requested in 8% even though my own spreadsheet brings it in at 9.4%. This could be due to my misestimating SelectHealth's enrollment number, or it could be because Regence Blue Shield cays they're raising rates 3.9% but the state claims it's 7% (although that should actually result in a higher average from the state, not lower...)

Delaware is pretty cut & dried: There's only one carrier, Highmark, offering ACA policies in the state. They're requesting a 13.0% average rate increase for 2019, and yes, they call out both the individual mandate being repealed and #ShortAssPlans being expanded by Trump and the GOP.

Unfortunately, they've redacted the specific percentages caused by those factors. The Urban Institute pegs it at 19.9%, but I err on the side of caution and only assume 2/3 of that amount, or right around...13%. If accurate, that means Highmark BCBSD would be keeping rates pretty much flat next year if those changes hadn't been made.

Arkansas has three carriers offering ACA individual market policies, but one of them is kind of/sort of split into two separate entities (QualChoice and QCA). Unfortunately, most of the key actuarial memo content has been redacted, so I'm missing data on market share for three of the four entries--Ambetter/Celtic is the only one which states outright their current enrollment number. For the other three I had to estimate based on last years data. For QCA and USAble (which is actually Blue Cross Blue Shield, for some reason), I had to sort of split the difference between the different entries to get the overall requested rate increases.

In terms of #MandateRepeal & #ShortAssPlans, the Urban Institute projected an 18.8 percentage point impact. 2/3 of that is 12.5%, so I'm estimating that without those factors, average unsubsidized Arkansas rates would be dropping by around 8% next year.

Arizona has only three carriers offering individual market policies next year. Blue Cross Blue Shield of AZ has nearly 40,000 enrollees and is keeping rates virtually flat, but specifically states that yes, they baked in extra costs to account for Congressional Republicans repealing the ACA's Individual Mandate and due to Trump's expansion of #ShortAssPlans (see screenshot below).

Centene is dropping rates by over 5 points. I don't know their exact enrollment/market share, so I'm forced to assume it's similar to last year's 95,000. Again, they call out both #MandateRepeal and #ShortAssPlans, but don't include a specific percentage for either (they did, but it was redacted in the public filing).

Finally, Cigna is dropping their 2019 premiums by a whopping 18.2% even with sabotage factors, which again are referenced in the filing. I don't know their enrollment either, but amd assuming it's roughly 16,000 since Arizona's total ACA indy market is around 150,000 people.

Only limited portions of Louisiana's actual rate filings are actually publicly available at either the SERFF database or the HC.gov Rate Review site, making it difficult to get a bead on the weighted averages. Fortunately, this article in The Advocate does the work for me:

Obamacare premiums to drop in Louisiana in 2019 after years of rate hikes

After seeing years of rate hikes, Louisiana residents getting health insurance through the Affordable Care Act’s individual exchange will see premiums drop in 2019 by an average of 6.4 percent.

The direction is an abrupt turnaround for the individual exchange, created under the ACA —commonly known as Obamacare — to offer insurance to people who don’t receive it through their jobs or other means. Until now, Louisiana’s individual market has weathered years of rising premiums, including a jump of 18.5 percent on average for 2018.

Alaska has only a single insurance carrier offering ACA-compliant individual market plans, so it should be a piece of cake to calculate their average premium change, since I don't have to calculate the relative market share.

Unfortunately, some carriers submit multiple filings for different lines of business even if they both use the same "Actuarial Memorandum" to justify the incresae...and often times the memo itself is redacted, with the critical data (covered lives, percent increases, dollar amounts, etc.) blocked out, making it kind of useless for my purposes. Such is the case with Premera Blue Cross Blue Shield, the sole ACA market carrier in Alaska. Thanks in large part to the state's successful reinsurance program, they're dropping rates by 7% on most of their policies, and by 10.3% on the rest...but I don't know the relative portion of each, so I can't be sure what the weighted average of the two is. The second listing is for Health Savings Account plans only, so I'm assuming the bulk of their enrollees have the first types of policies, which suggests roughly an 8% overall premium drop.

(see update below)

Last year Alabama had only a single insurance carrier, Blue Cross Blue Shield, offering individual market policies anywhere in the state. For 2018, a new carrier, Bright Health Insurance, jumped into the AL market. For 2019, both companies are lowering rates--BCBSAL is only dropping theirs slightly, but Bright clearly way overshot the mark out of the gate and is lowering their prices by 15.5% overall next year.

Unfortunately, neither of the filings clarifies just how many enrollees either has, so I don't know what the relative market share is; I'm going to assume that BCBS held onto about 90% of the total given their monopoly hold last year and the fact that Bright is a new/unknown player in the market (not to mention the fact that Bright seems to have overpriced their first year). Obviously I'll have to change this if I receive hard numbers to the contrary.

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.

The Missouri Insurance Dept. has released preliminary 2019 rate filings for the individual and small group markets. Interestingly, in addition to the ACA compliant rate changes, they also posted transitional policy rate changes as well, which is unusual.

Missouri's situation is pretty straightforward: Three existing ACA market carriers are sticking around, and a fourth one is jumping in (Medica). Since Medica is new to the market, they don't have any actual rate changes to speak of. The other three are requesting rate increases of 3.7%, 7.3% and -8.6% respectively; Celtic is dropping rates next year.

 

Monday afternoon there was a hell of a jaw-dropper out of the Empire State:

Gov. Cuomo just announced that he has directed Supt. Vullo to reject any individual market rate increase that included an increase to compensate for the repeal of the individual mandate

...Assuming that nothing else changes during the rate review process, this makes carriers that didn't associate a % of their rate request with the loss of the mandate big winners...and those who did, not so much.

Sure enough, after watching the half-hour speech by Cuomo, it sure as hell sounded like he was doing exactly that: Instructing the state insurance commissioner to only allow 2019 ACA individual market premiums to increase by around the 12.1% (on average) that they were expecting to go up with the ACA's individual mandate penalty in place instead of the roughly 24% (on average) that they said they'd have to raise them to cancel out the adverse selection impact of the mandate being repealed:

 

Note: This is a follow-up to a post I wrote back in early May which was itself based on an earlier analysis by the folks at the Kaiser Family Foundation.

For weeks now, I've been painstakingly analyzing and plugging in the preliminary 2019 rate change data for ACA-compliant individual market as each state submits their filings. As of today, I've compiled data for 18 states (+DC), comprising perhaps 40% of the total ACA individual market, give or take. The table below shows where things stand at the moment.

Those yellow and manilla cells at the bottom are not a typo: To the best of my estimates so far, the insurance carriers across these 19 markets are asking for average 2019 unsubsidized premium rate increases of around 10-11%...however, as far as I can tell, they would be keeping rates FLAT year over year (on average), for the first time since the ACA launched, if not for three sabotage efforts by Donald Trump and Congressional Republicans: Repeal of the ACA's individual mandate, and Trump's removal of restrictions on non-ACA compliant "Short-Term, Limited Duration" and "Association" plans, which I've shorthanded as simply #ShortAssPlans....and in fact would actually be dropping in quite a few states (or, in the case of Minnesota, dropping more than they already are set to with those factors):

UPDATED 6/22/18: Added Indiana and Iowa to the table.
UPDATED 6/25/18: Added Florida, Kentucky, Ohio and Texas* to the table
*(Texas only has about 1/3 of the total ACA individual market accounted for, so it could easily change)
UPDATED 7/3/18: Added Montana and Georgia to the table
UPDATED 7/13/18: Added Tennessee, updated Texas to add BCBSTX
UPDATED 7/16/18: Added Colorado
UPDATED 7/17/18: Added Nevada
UPDATED 7/19/18: Added California
UPDATED 7/20/18: Added Connecticut

NOTE: I originally missed two carriers (McLaren and Molina); thanks to Louise Norris for calling attention to my error. The entire post, along with the table, has been updated to reflect the updated numbers including all 11 carriers.

Also note that while the headline originally reflected what the average rate change would be without the CSR load sabotage factor introduced in 2017, I've decided to be consistent with other states and only include 2018 sabotage impact.

My home state of Michigan just posted their preliminary requested rate changes for the 2019 Open Enrollment Period, and unlike most of the other states which have released their early requests so far, Michigan is a pleasant surprise: An overall average requested premium increase of just 1.7%!

Also noteworthy: According to the filings, eight of the carriers are specifically projecting exactly a 5% mandate repeal factor, which is remarkably consistent (usually the projections are all over the place). HAP is slightly lower (4.4%) while Molina is higher (7.2%). Priority Health didn't mention this at all, but it's safe to assume it'd be roughly 5% for them as well.

Pages