ShortAssPlans

2018 MIDTERM ELECTION

Time: D H M S

Hat tip to Louise Norris for the heads up about the Kentucky Dept. of Insurance issuing their final rulings for 2019 ACA individual market and small group policy premiums:

DOI Completes Review of Individual and Small-Group Health Insurance Rate Filings

The Kentucky Department of Insurance (DOI) announced today that it has completed its review of the individual and small-group insurance rates filed in the Kentucky market. The rates will be used to calculate insurance premiums in the 2019 benefit year.

Kentuckians in the individual market will once again experience changes in premiums and plan offerings. The rates that will be used reflect an average rate increase of 4.3 percent for Anthem Health Plans of Kentucky (Anthem) and 19.4 percent for CareSource. Since the actual premium charged will vary by individual and the plan level selected, some individuals may see a decrease in rates.

This just in from the Florida Office of Insurance Regulation...

OIR Announces 2019 PPACA Individual Market Health Insurance Plan Rates  

TALLAHASSEE, Fla. – The Florida Office of Insurance Regulation (OIR) announced today that premiums for Florida individual major medical plans in compliance with the federal Patient Protection & Affordable Care Act (PPACA) will increase an average of 5.2 percent beginning January 1, 2019. Per federal guidelines, a total of nine health insurance companies submitted rate filings for OIR’s review in June with final rate determinations due by August 22, 2018. 

Following OIR’s rate filing review, the average approved rate changes on the Exchange range from a low of -1.5 percent to a high of 9.8 percent. This information can be located in the Individual PPACA Market Monthly Premiums for Plan Year 2019 document available here.

When I first ran the preliminary 2019 ACA individual market rate filings for Virginia way back in May, I concluded that the average premium increase will be around 13.4%. However, a lot has changed since then.

For one thing, Virginia expanded Medicaid to 400,000 low-income residents, which should help improve the ACA risk pool and in turn knocked the average rate increase down by 2.2 points, to around 11.3%.

For another, Anthem made a last-minute decision to expand their coverage areas in the state dramatically, which also provides much-needed competition for Optima in the Charlottesville area, among others.

With the deadline for submitting 2019 rate filings having passed a week or so ago, the approved rates from the various state insurance regulators have been popping up left and right. Today I took a look at the Arkansas Insurance Dept. website and sure enough, they've posted the approved filings for all 4 carriers on the individual market (as well as the small group market).

On the one hand, the statewide average rate increase hasn't changed much from the preliminary average; it dropped 0.4 points from 4.5% to 4.1%...and some of that change is simply because I had misestimated the actual enrollment/market share for a couple of the carriers.

On the other hand, in Arkansas, at least, it appears that the carriers don't think the repeal of the individual mandate and/or the Trump Administration's expansion of short-term and association health plans will have nearly as big of an adverse selection impact as other estimates/projections have...including my own.

It's been awhile since I last updated my "ACA Protection Spreadsheet", which is an attempt to track a whole mess of bills designed to protect the Affordable Care Act from sabotage at the federal level by the Trump Administration and Congressional Republicans. My last update was over a month ago, when Hawaii's Governor signed a law which locks in several ACA protections, including:

  • Ensure that young adults can continue to remain on their parents’ health insurance plans until age 26
  • Prohibit insurers from using applicants’ gender to set premiums
  • Prohibit insurers from rejecting an application based on an applicant’s medical history, or imposing coverage exclusions based on pre-existing conditions.

Today, however, there were major developments regarding #ShortAssPlan restrictions (and a few other important patient protection bills) in three states: Two positive, one negative.

CALIFORNIA:

Busy day today! State insurance regulators around the country appear to have decided to start posting approved 2019 ACA rate filings all at once; within the past week, Vermont, Ohio, Delaware and North Carolina have posted theirs...and now you can add Georgia to the list:

The Obamacare rates for next year are in, and it’s a first: Rates are going down.

Following years of steep price hikes, two of the four companies that offer plans on the Affordable Care Act exchange in Georgia, also known as Obamacare, have proposed to lower their rates next year from what they charged in 2018.

According to figures for the individual insurance market released Thursday by the state Department of Insurance, Blue Cross Blue Shield of Georgia is proposing a tiny decrease in premiums for next year, with 2019 premium prices that are on average 0.3 percent lower than 2018’s premiums. Alliant Health Plans is decreasing its premiums by 10 percent.

Over at The Hill, Nathaniel Weixel has a great roundup of some of the actions various states are taking to counteract Donald Trump's potentially illegal sabotage of the Affordable Care Act:

The Department of Health and Human Services is urging states to cooperate with the federal government, but instead, insurance commissioners are panning the new plans as "junk” insurance and state legislatures are putting restrictions on their sales.

State insurance officials argue that, despite being less expensive than ObamaCare plans, the short-term plans are bad for consumers and aren't an adequate substitute for comprehensive insurance.

“These policies are substandard, don’t cover essential health benefits, and consumers at a minimum don’t understand [what they’re buying], and at worse are misled,” California Insurance Commissioner Dave Jones (D) said.  

In my Tennessee 2019 rate filing analysis last month, I noted the good, the bad and the ugly:

  • The good news was that average unsubsidized 2019 ACA individual market premiums were expected to drop by about 5.7% after years of double-digit rate hikes.
  • The bad news was that due specifically to various types of deliberate sabotage by the Trump Administration and Congressional Republicans (primarily repeal of the individual mandate and expansion of #ShortAssPlans), that 5.7% drop was still a good 12 points or so higher than it otherwise would have been.
  • The ugly news was that due specifically to the Trump Administration's utterly unnecessary decision to freeze Risk Adjustment fund transfers in response to a lawsuit out of New Mexico, 2019 premiums would be hundreds of dollars higher still than they should have been for Blue Cross Blue Shield of Tennessee's 113,000 enrollees:

HERE WE GO AGAIN...

As regular readers know, each year I analyze hundreds of insurance carrier rate filings for the following year, then crunch the numbers to get an estimate of how much average premiums will increase (or in a few cases, decrease!) statewide.

As they also know, last year and again this year I've expanded on this by breaking out the portion of the annual rate increase which can be tied directly to sabotage efforts by the Trump Administration and Congressional Republicans. For 2018, this boiled down to roughly 17 points of the total nationwide increase being sabotage-related. It varied greatly by state, carrier and plan, but nationally, I estimated that without last year's ACA sabotage efforts, average premiums would have gone up around 11% instead of around 28%.

Annnnnnnnd finally, the least-populated state of them all...which also happens to be suffering from the highest average monthly premiums for unsubsidized individual market enrollees: Wyoming.

There's only a single carrier in the Equality State (seriously...that's their motto; who knew?), Blue Cross Blue Shield. They're actually looking to lower rates by just a smidge (0.25% on average).

However, once again, the Urban Institute projected that there'd be roughly an 18.6% increase factor due to the ACA's individual mandate being repeale and short-term & association plans being expanded by the Trump administration.

Assuming just 2/3 of that to play it safe, that still means that unsubsidized enrollees would have been looking at roughly a 12% drop in their 2019 premiums without those measures...a difference of over $120/month, or a whopping $1,400 more apiece next year. Ouch.

The most noteworthy thing about West Virginia's 2019 filings that I can see is that CareSource is expanding their state coverage from 10 counties to 35 counties, and the confirmation that West Virginia will remain one of the few states sticking with a Broad Load CSR strategy for reasons unknown next year (the state insurance commissioner might change their tune, however, now that CMS has done a complete 180 degree turn and has officially come out in favor of Silver Switching).

In any event, the statewide average premium hike appears to be around 14.9%...but once again, much of this is due to the ACA's individual mandate being repealed and Trump opening the floodgates on #ShortAssPlans.

At $843/month, West Virginia has one of the highest average monthly premiums in the country...and instead of only going up nominally next year, thanks to #ACASabotage, unsubsidized enrollees will likely have to pay a whopping $1,300 more apiece next year.

Utah has four carriers offering ACA-compliant individual market plans. Two of them (BridgeSpan and Regence BCBS) only offered their policies off-exchange this year; I'm not sure what the status is for either one in 2019. I can only find hard enrollment data for one of the four (Regence), so I'm estimating the other three based on a combination of last year's numbers and the total estimated individual market size in Utah from 2017. Because of this, consider the Utah estimates to be even rougher than some other states.

Having said that, there's one interesting extra sabotage factor to consider for the University of Utah rate filing: They note that they've added an extra 10.3% to their 2019 rates specifically tied to last year's Cost Sharing Reduction (CSR) cut-off. I presume they chose not to bake the CSR load into their rates this year, but I don't think Utah went the "mixed load" route so who knows?

In any event, as far as I can tell, this means around a 14-point #ACASabotage factor, between CSR load, mandate repeal and #ShortAssPlans.

South Dakota has two ACA indy market carriers, Avera and Sanford. The relative enrollment market shares are based on last year's numbers. The 14.4% #ACASabotage impact assumes 2/3 of the Urban Institute's projections to err on the side of caution.

THe average unsubsidized SD indy market enrollee pays $624/month this year; instead of that dropping by around $68/month, it's expected to increase by $22...for a total monthly difference of $90.

Assuming that's accurate, this means unsubsidized SD residents will be paying over $1,000 more apiece next year than they'd otherwise have to.

The only confusing thing about South Carolina's 2019 rate filings is that I'm not sure whether the "BlueChoice Health Plan" should be rolled in with the main Blue Cross Blue Shield of SC population. Carriers often have multiple listings in the same state for different policy lines, but they're generally listed under the same official corporate name. In this case, "BlueChoice" (which is clearly still part of BCBS) has a completely seaparate listing.

The BCBS filing clearly states the number of enrollees as around 203,000 people. The BlueChoice listing doesn't give a membership number, but appears to be roughly 6,800 people based on the full premium dollars they received in all of 2017 ($53.5 million divided by 12 months, divided by the statewide average of $654/month this year). This doesn't really make much difference, however, since BCBS still holds nearly 99% of the market anyway.

Assuming an 11.5% #ACASabotage factor (mandate repeal + shortassplans), this translates into unsubsidized enrollees having to pay an extra $900 than they'd otherwise have to (a 9.2% rate increase instead of a 2.3% rate drop).

Oklahoma is pretty clear cut: BCBSOK holds nearly all of the ACA-compliant market share, with CommunityCare HMO having a small number of off-exchange enrollees (the numbers are estimates based on last year's figures).

The Urban Institute projected an 18.4% rate increase due to #MandateRepeal and #ShortAssPlans. BCBSOK doesn't go into specifics about the impact, but does list both of these as significant factors. Knocking 1/3 off this projection gives around 12.4%.

Unsubsidized Oklahoma enrollees are paying an average of $694/month in 2018. Without ACA sabotage, they'd likely see this drop to around $595; instead, they're likely looking at paying roughly $681/month, or an additional $1,033 apiece.

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