OE6

2018 MIDTERM ELECTION

Time: D H M S

Last month, after much painstaking research and analysis, I concluded that unsubsidized ACA-compliant individual market enrollees (both on & off the exchanges) are paying an average of around $960 this year (~$80/month) more in healthcare premiums nationally in 2018 than they otherwise would be if not for the various forms of ACA sabotage carried out by Donald Trump and Congressional Republicans last year.

Again, it's important to clarify that this is $960 more (around 17% more) in addition to non-sabotage-related factors such as normal medical expense inflation (around 7%), the reinstatement of the ACA carrier tax (about 2%) and other various/sundry factors (around 2%).

Back in mid-April, I crunched a bunch of numbers and concluded that around 6.5 million people enrolled in unsubsidized ACA-compliant individual market policies are, on average, paying an additional $960/year ($80/month) for their policies this year due specifically to last year's sabotage efforts by Donald Trump and Congressional Republicans. This is separate from other factors such as medical trend and the reinstatement of the ACA carrier tax. The actual 2018 "Trump Tax" ranges from as little as almost nothing at all in Vermont and North Dakota to as high as $1,500 per enrollee in Mississippi and Pennsylvania.

The 2018 sabotage impact was mainly due to 1) CSR reimbursement funding being cut off; 2) uncertainty over individual mandate enforcement; and 3) a mish-mash of Open Enrollment changes including cutting the time window in half, slashing marketing/assistance budgets by 90% and 40% respectively and so forth.

 

The Kaiser Family Foundation just released an important new study which proves everything I've been saying for the past year and a half: After years of turmoil, the ACA-compliant individual market had finally quieted down and reached equilibrium last year...right up until Donald Trump, combined with total GOP control of the federal government, deliberately came in like a wrecking ball and messed everything up again:

Concerns about the stability of the individual insurance market under the Affordable Care Act (ACA) have been raised in the past year following exits of several insurers from the exchange markets for 2017, and again last year during the debate over repeal of the health law.

A huge shout-out to Jesse O'Brien for the heads up on this (as well as for posting some of the actual filing data).

Oregon just became the 4th state to submit their preliminary 2019 ACA individual market rate filings, and while the expected increase is smaller than expected on average (in part due to Oregon's strict control of short-term plans), repeal of the individual mandate by Congressional Republicans and Donald Trump are still responsible for the vast majority of the rate increase.

Normally, I don't start posting natoinal projections for my annual Rate Hike Project until I have at least filing data for at least a dozen or so states because the national weighted average jumps around so much early on. A "national average" of, say, 10% based on numbers from, say, Vermont, Wyoming and the District of Columbia (collective population: 1.9 million people) is gonna change radically once you add California or Florida to the mix if they're looking at a 20% hike, for example.

Having said that, seeing how advocacy organization Protect Our Care has decided to launch their own version of my Rate Hike Project, and seeing how I do have preliminary 2019 rate increase projections from at one large state (Virginia) and two mid-sized states (Maryland and Oregon), I've decided to go ahead and start posting the national projections early, with a major caveat that the national average will likely change dramatically until at least 2/3 of the states have been plugged in.

Well. There you have it:

.@SeemaCMS bluntly says the uninsured rate will continue to rise because of rising premiums. "At some point, people can't afford coverage." #PostLive

— Alice Ollstein (@AliceOllstein) May 15, 2018

I think Albert said it best (and it appears to apply to some women as well):

 

Given how progressive Vermont is, you'd think that they'd be doing as much as possible to batten down the hatches in order to avoid or mitigate the latest wave of sabotage efforts from the Trump Administration and the GOP...and you'd mostly be correct.

Some of the work on that front has already been done. For one thing, Vermont (along with Massachusetts and the District of Columbia) merges their individual and small group market risk pools together, which helps smooth out premium increases and overall morbidity across a larger risk pool. For another, Vermont has fully embraced ACA provisions such as Medicaid expansion and operating their own full exchange, of course. Vermont, along with a few other states, also has pretty strict rules in place limiting both short-term and association healthcare plans, so that portion of Trump's sabotage attack is neatly cancelled out already.

Louise Norris is an awesome source for all sorts of healthcare policy/insurance data, but she's especially on top of developments in her home state of Colorado, where she and her husband Jay run a small brokerage outlet.

Today Jay and Louise have a couple of interesting tidbits out of The Centennial State (yeah, I had to look up their nickname myself).

First, according to Jay (via the Connect for Health Colorado exchange itself), as of May 7, 2018, C4HCO had exactly 142,474 people enrolled in effectuated ACA exchange policies statewide. This is noteworthy mainly because 161,764 people selected Qualified Health Plan (QHP) policies during the 2018 Open Enrollment Period.

That's (sort of) an 88% retention rate through early May. I say "sort of" because this presumably includes some amount of churn (if 100 people drop coverage and 100 off-season enrollees sign up, that'd be a net change of zero). Even so, it's actually slightly better compared to prior years, when the national effectuation number had usually dropped to around 87% by the end of March.

Hot on the heels of Virginia, Maryland is the 2nd state to post their preliminary 2019 unsubsidized ACA policy rate increase requests. According to Paul Demko of Politico...

Insurers selling Obamacare plans in Maryland are again seeking huge rate increases for 2019, but they could be knocked down significantly by a reinsurance program the state hopes to implement for next year.

CareFirst BlueCross BlueShield wants to increase rates on average by 18.5 percent on its HMO plans, which account for more than half of the individual market this year. Kaiser Permanente, the only other insurer selling on the exchange, is seeking a 37.4 percent average increase on its HMO plans, which cover just over a third of Obamacare customers.

A couple of days ago, I posted that Virginia has become the first state out of the gate with their preliminary 2019 premium rate requests for ACA individual policies. However, I made sure to emphasize that these are preliminary requests only; carriers often resubmit their rate change requests more than once over the course of the summer/fall, and even that may not match whatever the final, approved rate changes are by the state insurance commissioner.

In addition, I generally try to make it understood that there's alotof room for error here--the weighted averages are based on the number of current enrollees, but of course that number can change from month to month as people drop policies or sign up during the off-season (via Special Enrollment Periods). Even then, the rate filing paperwork is often vague or confusing about just how many enrollees they actually have in these plans. Sometimes wonks are reduced to taking the number of "member months" and dividing by 12 to get a rough idea of how many people are enrolled in any given month. Sometimes the only number of enrollees available are from last year, which could bear zero resemblence to how many are currently enrolled. Sometimes the only number available is how many people the carrier expects to enroll in their policies next year. And so on.

Aside from Virginia, it's likely going to be another month or so before the 2019 ACA policy rate filings start trickling in, since the deadline for initial rate requests isn't until late June in most states. However, there's some interesting non-ACA policy filing stuff which is available as well. Given all the concern about non-ACA compliant policies siphoning healthy people away from the ACA market, I figured I should take a look at a few of these.

Here in Michigan, I've found three such filings: One is for "transitional" plans from Golden Rule (a subsidiary of Unitedhealthcare, I believe). The other two are for "short-term" plans (the type which Donald Trump is basically removing any regulation on).

First up, Golden Rule:

IMORTANT UPDATE: As I suspected, it turns out that the stray rate filing posted to the California Insurance Dept. website a few days ago was posted prematurely, doesn't reflect the carrier's final* rate filing, and has since been pulled from the California Insurance Dept. website.

I've been asked to remove the filing data, and seeing how there's nothing nefarious about it (I wasn't "whistleblowing" evidence of anything criminal/unethical), I'm complying with that request. Since everything in the post related to that data, there wasn't much point in keeping the rest of it either.

*(Yes, I'm aware that none of these early filings are "final" since they tend to be revised/resubmitted throughout the summer/fall, but you know what I mean.)

Covered California Analysis Shows Major Declines in New Enrollment Nationally and Identifies Policies That Could Lower Premiums in 2019

  • Enrollment in the federally facilitated marketplace has dropped 9 percent over the past two years, with a nearly 40 percent drop in new enrollment, while enrollment in state-based marketplaces remained steady during the same period.

Nothing new under the sun here; this is the core of what I do at ACASignups.net. In fact, this press release underplays the point slightly: The official enrollment tallies are down 10% on the federal exchange since 2016 and up 1.5%, although the discrepancy might be partly due to Kentucky shifting from state-based status to federal status in 2017.

A few weeks ago I posted an entry title, "Will Trump's HHS Dept. do the stupidest thing possible? Reply Hazy; Try Again Later."

The "stupidest thing possible" being referred to was whether or not CMS Administrator Seema Verma is planning on putting the kibosh on Silver Loading and the Silver Switcharoo starting in 2019:

The head of the Centers for Medicare and Medicaid Services would not say Thursday if the Trump administration is considering setting limits on how insurers that sell Obamacare plans structure subsidies for their customers.

"I'm not going to comment on the agency's deliberations," CMS Administrator Seema Verma said when asked by the Washington Examiner about rumors that had circulated about the issue. When pressed about whether any conversations had occurred, Verma said, "I'm just going to leave it at that."

Last month I noted that while Congressional Republicans spent all of 2017 desperately attempting to "blow up" the Affordable Care Act via a combination of legislation, the Trump Administration simultaneously tried to tear down the law via various regulatory sabotage efforts. This year the GOP Congress appears to have mostly given up on their mischief (they did manage to partially wound the ACA by repealing the individual mandate), the Trump Administration is doubling down on regulatory sabotage, laying what I've termed "Regulatory Siege" to the law.

In my mind, "phase one" included the non-legislative stuff Trump did last year, including stuff like cutting off CSR reimbursements, slashing the Open Enrollment Period in half, slashing marketing funding by 90%, slashing the outreach budget by 40% and so on. "Phase two" includes the previously-announced #ShortAssPlans executive order, CMS allowing work requirements for Medicaid and so forth (individual mandate repeal belongs here as well, although that was legislative, not regulatory...although there's overlap as you'll see below).

Yesterday brought Phase Three.

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