Reinsurance

2019 OPEN ENROLLMENT ENDS (most states)

Time: D H M S

Wisconsin has an interesting situation. On the one hand, the state has what should be a robust, highly-competitive individual insurance market,with over a dozen carriers offering policies throughout the state. Granted, some of them are likely limited to only a handful of counties, but in theory they should be doing pretty well compared to rural states like Oklahoma or Wyoming, which only have a single carrier on the exchange.

On the other hand, last year Wisconsin ahd among the highest average premium rate increases in the country. Rates were projected to increase by an already-awful 36%, but when the dust settled the average unsubsidized ACA enrollee in Wisconsin was paying a whopping 44% more than they did in 2017 (it was around 45.8% higher as of the end of Open Enrollment but later dropped a bit as the year has passed and net attrition has tweaked the enrollment base).

The Reinsurance Train keeps chugging along.

In 2017, three states established their own ACA market reinsurance program utilizing the ACA's Section 1332 State Innovation Waiver provision to keep unsubsidized premiums from spiraling out of control in 2018 and beyond: Alaska, Minnesota and Oregon.

UPDATE 3:50pm: OK, it sounds like you can completely disregard all the Medicaid-related stuff below; apparently there was a communication error. I've confirmed with the Whitmer campaign that the proposed reinsurance plan would not be tied in with Michigan's ACA Medicaid expansion program at all, nor would it have any impact on the Medicaid eligigibility threshold, which means this would indeed be a standard ACA individual market reinsurance program after all...which is what I assumed in the first place, and which would be perfectly fine!

Note that Chad Livengood has revised his article and headline accordingly, with a note at the bottom regarding the correction.

A few minutes ago I posted about North Dakota's approved 2019 rate hikes, which are coming in at a mere 3.2% on average (but which would likely be dropping nearly 20 points without both last and this year's #ACASabotage factors).

However, there was something else equally interesting included in the ND DOI press release: Like Montana and several other states, North Dakota is also considering jumping onboard the state-based reinsurance waiver train!

via Montana Standard:

The state is exploring whether a Montana-run reinsurance program would help lower the premiums people pay when buying their health insurance on the federal marketplace, in some cases by 10-20 percent.

Yes. Yes, it would.

...Montana Gov. Steve Bullock and Department of Administration Director John Lewis are creating a 13-person working group to explore how a state-run reinsurance program might work in Montana. The group will use information from a recent study commissioned by the Montana Healthcare Foundation looking at what reinsurance could mean for the state.

The study shows reinsurance could lower premiums that have risen by double digits in recent years. Those rates could drop anywhere from 9.6 percent to nearly 30 percent on extreme ends of the spectrum, according to the study.

When Maryland insurance carriers originally submitted their proposed 2019 premium changes back in May, it looked pretty grim...they were expected to average around 29.5% statewide for the ACA-compliant individual market., increasing from around $631/month on average to roughly $817/month for unsubsidized enrollees.

Thanks to swift, bipartisan action on the part of the Democratically-controlled Maryland state legislature and the Republican Governor, Maryland was able to pass several bills which partially negated or cancelled out Trump/Congressional Republican sabotage of the Affordable Care Act. In particular, they passed laws which locked in current restrictions on both short-term plans and association health plans (the types of "junk policies" which Trump is pushing hard to expand upon)...along with an extremely robust reinsurance program.

Back in April, I started an ambitious project which set out to track every legislative or regulatory measure taken by every state to counter, cancel out or mitigate sabotage of the Affordable Care Act by the Trump Administration and Congressional Republicans. It resulted in this color-coded spreadsheet, which lists dozens of bills, proposals, amendments and so on at various stages of completion.

The bad news is that project has proven to be too large for me to keep up with--there's simply too many bills, too many stages and too much other stuff going on for me to keep track of it all.

The good news is that the Center for American Progress (which has slightly more resources than I do) has launched their own version of this project, and it's very slickly done:

CMS Administrator Seema Verma is difficult to get a read on. On the one hand, she glories in trashing the ACA every chance she gets while happily endorsing nearly every effort to undermine or sabotage it, including repeal of the individual mandate, slashing the marketing and outreach budgets and so forth. Last year she was even busted trying to (effectively) blackmail the insurance carriers at large by offering to push through CSR reimbursement payment in return for them supporting the GOP's Obamacare repeal bill.

At the same time, she--like Trump's first HHS Secretary, Tom Price--also seems to have a soft spot for one particular type of ACA improvement program: Reinsurance.

A few weeks ago, I posted about New Jersey's preliminary 2019 ACA-compliant individual market rate filings. At the time, the official New Jersey Dept. of Banking & Insurance specifically stated that:

  • Because Congressional Republicans repealed the ACA's Individual Mandate Penalty, carriers were planning on increasing 2019 premiums by 12.6% on average, in part to account for the adverse selection which was expected to happen next year.
  • However, thanks to the Democratically-controlled New Jersey state legislature and Governor swiftly reinstating the ACA individual mandate, actual 2019 rate filings are only expected to increase rates an average of 5.8%, saving the average unsubsidized indy market enrollee around $470 apiece next year.
  • Finally, the NJ legislature also passed, and Governor Murphy signed into law, a robust reinsurance bill which, if approved by CMS, is expected to lower unsubsidized 2019 premiums by an additional 15 percentage points, for a final 2019 average premium reduction of around 9.2%.
  • It's also important to understand that New Jersey's portion of the funding for the proposed reinsurance program will be coming from the revenue generated by the reinstated mandate penalty itself.

Hot on the heels of Anthem's announcement that they're significantly expanding their ACA market coverage throughout Virginia comes another piece of welcome news:

Gov. Ralph Northam’s administration will convene a new work group on Monday to consider options to stabilize soaring premiums in Virginia’s health insurance market.

The Virginia Market Stability Group will consider a wide range of options to lower insurance premiums expected to average more than $833 a month next year, making coverage unaffordable to people who don’t qualify for federal subsidies for premiums or out-of-pocket expenses in the marketplace established by the Affordable Care Act.

...But one option could trump all others — a state budget plan to request a federal waiver for a “re-insurance” program in Virginia that would help defray the costs for the most expensive patients and relieve the expense for others by lowering the risk.

Hot on the heels of Wisconsin's ACA reinsurance program being approved by CMS comes another reinsurance waiver approval, this time for Maine:

The U.S Department of Health and Human Services and the U.S. Department of the Treasury (the Departments) approved Maine’s application for a State Innovation Waiver under section 1332 of the Patient Protection and Affordable Care Act (PPACA) (the waiver). Maine’s application seeks to reinstate a reinsurance program called the Maine Guaranteed Access Reinsurance Association (MGARA) from 2019 through 2023. As a result of the waiver approval, more consumers in Maine may have coverage, consumers will see lower premiums, and the state will receive Federal funds to cover a substantial portion of state costs for MGARA.

Maine’s State Innovation Waiver under section 1332 of the PPACA is approved subject to the state accepting the specific terms and conditions (STCs). This approval is effective for January 1, 2019 through December 31, 2023.

Summary of Maine’s State Innovation Waiver under section 1332 of the PPACA Application

This Just In...

State’s Market Stability Workgroup Recommends Immediate Action to Protect Rhode Islanders from Federal Threats to Health Insurance Access and Affordability

Posted on June 27, 2018 | By HealthSource RI

EAST PROVIDENCE, R.I. (June 27, 2018) – Rhode Island must act “without delay” to protect consumers from rising health coverage costs brought on by federal policy changes according to a report issued to Governor Raimondo by the state’s Market Stability Workgroup.

“People representing a wide variety of viewpoints engaged in lively discussions over the course of 8 weeks,” said Workgroup co-chair Bill Wray, Chief Risk Officer at the Washington Trust. “The fruits of those discussions are in this report. All of us – consumer advocates, business groups, health insurers and providers – were able to broadly agree on how best to protect Rhode Island’s insurance markets.”

Shout-out to Mitchell Stein for this heads up: The Maine Bureau of Insurance has posted their preliminary 2019 individual and small group policy premium rate filings.

One important twist: A few months back I remember reading that Maine, like several other states, was considering establishing some type of reinsurance program along the lines of successful programs in Alaska, Minnesota and Oregon. I also remember reading that the Maine version was unusual--it would actually involve reestablishing an old, discontinued state program which was still on the books but had been mothballed for years. However, I never got around to doing a write-up about it.

Anyway, it looks like the program (Maine Guaranteed Access Reinsurance Association, or MGARA for short), is indeed being ramped back up:

Last week I noted that the New Jersey state legislature, along with new Governor Phil Murphy, has moved quickly to pass and sign into law a number of critical ACA protection bills, to:

  • Reinstate the ACA's individual mandate penalty,
  • Establish a robust reinsurance program to significantly lower insurance premiums for individual market enrollees,
  • Protect people from out-of-network "balance billing", and
  • Cancel out Trump's expansion of "Association Health Plans"

In addition, New Jersey already outlawed "Short-Term Plans" (and "Surprise Billing") before the ACA was passed anyway.

Well, until today, there was some lingering doubt about the first two bills (which are connected...the reinsurance program would be partly funded by the revenue from the state-level mandate penalty), as Gov. Murphy was reportedly kind of iffy about signing them. As I understand it, he's been supportive of both ideas but is concerned about the potential budget hit in case the mandate penalty revenue doesn't raise enough to cover its share of the reinsurance program.

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