New Mexico

The contrast in how a completely Republican-held state government like Utah and a completely Democratic-held state government like New Mexico deal with Medicaid is pretty astonishing.

In Utah, just four months ago the public voted, clearly and unequivocally, to enact a full expansion of Medicaid to all adults earning up to 138% of the Federal Poverty Line...but the GOP state House, Senate and Governor decided to ignore the voters and override their will by cutting the expansion down to a 100% FPL cap, including work requirements, which will cover tens of thousands fewer people while costing the state $50 million more.

In New Mexico, meanwhile, a newly-enabled Democratic trifecta (I believe both houses of the state legislature were already held by Dems, but the Governorship flipped from Republican Susana Martinez to Democrat Michelle Lujan Grisham) has been on a tear in their first month and a half:

As always, Louise Norris has the skinny:

In September 2018, the New Mexico Office of the Superintendent of Insurance (OSI) and Health Action NM (an advocacy group for universal access to health care) presented details about potential state actions to stabilize the individual market. OSI has the authority to regulate some aspects of the plans, including maximum duration, but they noted that legislation would be needed for other changes, including minimum loss ratios and benefit mandates.

New Mexico’s insurance regulations were amended, effective February 1, 2019, to define short-term plans as nonrenewable, and with terms of no more than three months. The regulations also prohibit insurers from selling a short-term plan to anyone who has had short-term coverage within the previous 12 months.

Things have been happening so quickly of late that I'm getting farther and farther behind on some important healthcare policy developments, particularly at the state level. There are two extremely important Public Option announcements which could be game changers if they make it through the legislative process.

Since I don't have time to do full write-ups on either one right now, I'll just present these summaries:

My friend and colleague Colin Baillio, policy director of Health Action New Mexico, has been working on this for a long time, and it looks like this project has finally entered the legislative stage:

LUJÁN APPLAUDS INTRODUCTION OF MEDICAID BUY-IN LEGISLATION IN NEW MEXICO

Louise Norris gave me a heads up the other day...a very early heads up:

NM will operate its own exchange platform starting with the 2021 plan year

New Mexico has a unique exchange; the state runs the small business portion, and while the individual exchange is also technically state-run, Healthcare.gov is used to enroll people in individual insurance (ie, a federally-supported state-based marketplace). But the exchange is planning to establish its own enrollment platform that will be in use by the fall of 2020.

Normally I'd just use a snippet of the entry, but Norris manages to cover all the relevant angles in just a few paragraphs; I think she'll be OK with me cribbing more of it:

Initially, the state had planned to establish a state-run website for individual enrollments fairly soon after the exchanges went live in the fall of 2013, and that was still in the works until early spring 2015. But in April 2015, the exchange board voted to continue to use Healthcare.gov, as that was viewed as the less-costly alternative.

Hmmm...OK, this is rather curious.

New Mexico was one of the earlier states to post their initial, requested 2019 ACA individual market premium hikes back in June. At the time, the five carriers asked for rate increases ranging from a slight drop (-0.4% for Molina) to as high as an 18.5% increase for Presbyterian Health, which is currently only offering off-exchange policies this year. Based on their preliminary filings, New Mexico was looking at a weighted average increase of around 10.0% next year, which would have been more like 4% if not for this years sabotage efforts by Trump and the GOP (mandate repeal & expansion of #ShortAssPlans):

As usual, Louise Norris has the skinny:

Rate filings were due in New Mexico by June 10, 2018, for insurers that wish to offer individual market plans in 2019. Insurers that offer on-exchange coverage have been instructed by the New Mexico Office of the Superintendent of Insurance (NMOSI) to add the cost of cost-sharing reductions (CSR) only to on-exchange silver plans and the identical versions of those plans offered off-exchange (different silver plans offered only off-exchange will not have the cost of CSR added to their premiums).

Remember this from a few weeks back?

Insurers That Filed Wrong Rates Told By CMS They Can't Sell Plans Through Mid-November

An issuer whose final CMS-approved rates don’t account for the loss of cost-sharing reduction payments is being told by the agency that they won’t be able to sell plans until healthcare.gov data is refreshedeven though this would mean the carriers are even more crunched for time to sell their plans during the shortened open enrollment period.

UPDATE: It looks like this issue may be limited to a single carrier in New Mexico; I've changed the headline and graphic accordingly...but it might be an issue in other states as well; if so I may have to change it back again...

Fantastic (if migraine-inducing) scoop by Susannah Luthi of Inside Health Policy (paywall):

Insurers That Filed Wrong Rates Told By CMS They Can't Sell Plans Through Mid-November

An issuer whose final CMS-approved rates don’t account for the loss of cost-sharing reduction payments is being told by the agency that they won’t be able to sell plans until healthcare.gov data is refreshed– even though this would mean the carriers are even more crunched for time to sell their plans during the shortened open enrollment period.

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.

This just in...

New Mexico Health Connections, the nonprofit co-op insurance company formed under the Affordable Care Act, is selling its small group and commercial business to a for-profit company under a restructuring plan that will create a new insurance company that will be able to go after business the struggling nonprofit couldn’t.

...The Washington, D.C.-based Evolent will acquire NMHC’s 22,000 commercial members. NMHC will continue to exist with a few employees and presumably continue to sell individual policies on the New Mexico Health Insurance Exchange. NMHC has 10,000 individual members through the insurance exchange.

...Hickey told ABQ Free Press that the deal will allow the new firm to go after business that NMHC couldn’t, things like Medicare Advantage, federal employees and, eventually, Medicaid. It also gives the new firm capital reserves that NMHC didn’t have, he added.

A week ago, Vox's Sarah Kliff reported that the Trump Administration was slashing the 2018 Open Enrollment Period advertising budget by 90% and the navigator/outreach grant budget by nearly 40%. As I noted at the time, the potential negative impact of these moves on enrollment numbers this fall--coming on top of the period being slashed in half, the CSR reimbursement and mandate enforcement sabotage efforts of the Trump/Price HHS Dept. and the general confusion and uncertainty being felt by the GOP spending the past 7 months desperately attempting to repeal the ACA altogether could be significant. In states utilizing the federal exchange (HealthCare.Gov), 2017 enrollment was running neck & neck with 2016 right up until the critical final week...which played out under the Trump Administration, which killed off the final ad/marketing blitz.

Result? A 5.3% total enrollment drop (or 4.7% if you don't include Louisiana, which expanded Medicaid halfway through the year) via HC.gov, while the 12 state-based exchanges--which run their own marketing/advertising budgets--saw a 1.8% increase in total enrollment year over year.

New Mexico's Insurance Superintendent has released their 2018 rate hike request filings.

The database at the link above doesn't include the enrollee market share numbers; for that I had to dig up the actual filings at the SERFF database. Blue Cross Blue Shield and Presbyterian seem to be assuming no significant TrumpTax next year (which makes sense, since both will be off-exchange only, thus not subject to CSR payment concerns). Molina's filing is kind of odd--they seem to assume that CSR payments will be made...but that the individual mandate won't be enforced, which seems rather backwards to me (most TrumpTax filings assume neither will be enforced, or that the mandate will but CSR payments won't).

New Mexico is one of five states (also including Nevada, Oregon, Hawaii and Kentucky) which technically operate their own state-based ACA exchange, but utilize HealthCare.Gov as their website enrollment platform. As such, their enrollment numbers are usually only released along with the other three dozen states on the federal exchange.

However, once in awhile they post the enrollment numbers themselves; today is such a day:

@charles_gaba NMHIX: 52,006 total signups - almost as much as last year. Still anticipating a surge as NMHIX continues ads and outreach.

— Colin (@colinb1123) January 27, 2017

The breakout here is 36,579 renewals + 15,427 new enrollees, or a 70/30 split.

Last year, New Mexico's total came in at 54,865 QHP selections, so they've hit 95% of that so far.

My original target for New Mexico for this year was 60,000, though I've knocked this down to 57,000 more recently. They're at around 91% of that so far, with less than a week to go. They'll have to add another 5,000 people in the final surge, which seems unlikely, but who knows?

In New Mexico, assuming 57,000 people enroll in private exchange policies by the end of January, I estimate around 25,000 of them would be forced off of their private policy upon an immediate-effect full ACA repeal, plus another 260,000 enrolled in the ACA Medicaid expansion program, for a total of 285,000 residents kicked to the curb.

As for the individual market, my standard methodology applies:

When I first ran the numbers for New Mexico back in May, the average requested rate hike for the indy market appeared to be about 24.9%. Since then, however, there have been three major changes: First, Presbyterian Health Plan decided to drop off the exchange (although they'll still be around off-exchange). Second, it looks like CHRISTUS bumped up their request from 12.3% to 15.78%; and third, Molina Healthcare, which had been requesting a refreshingly modest 3.8% hike, resubmitted their request at a much higher 24% average increase.

Three of the 5 carriers had their final requests approved exactly as is by state regulators. CHRISTUS and Molina have yet to be approved, but based on a lengthy online conversation with someone very much in the know about the New Mexico health insurance market, I'm highly inclined to believe that both of their final asks will be approved as is as well.

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