Tennessee

2019 OPEN ENROLLMENT ENDS (most states)

Time: D H M S

When I last posted about 2019 ACA-compliant individual market premium changes in Tennessee back in August, I noted that premiums statewide had gone from dropping 5.7% to dropping 10.8% on average after the Trump Administration first stated that they were going to unnecessarily "freeze" the ACA's Risk Adjustment fund transfers in response to a lawsuit ruling only to reverse themselves a week or so later and state that they were going to go ahead and process RA fund transfers after all.

In other words, the Trump Administration once again deliberately caused a panic across the industry only to "save" the industry from the very threat which they had posed in the first place.

In any event, here's what I thought the Tennessee's premium situation looked like when the dust settled:

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:

 

Less than three weeks ago, the Centers for Medicare & Medicaid (CMS) dropped a Friday night bombshell: In response to a judicial ruling in a federal lawsuit brought by a small New Mexico insurance carrier, CMS had decided to temporarily "freeze" the transfer of roughly $10.4 billion in Risk Adjustment funds either owed to or owed by several hundred carriers nationwide.

The whole story about how the Risk Adjustment (RA) program, what the lawsuit is about and why the funds were frozen gets pretty wonky, but the bottom line is...

A few days ago I noted that Blue Cross Blue Shield of Tennessee, which holds over 50% of TN's ACA-compliant individual market, specifically noted in their individual market rate filings that while they're lowering rates by 10.9% on average in 2019, they had been planning on lowering rates considerably more prior to the bombshell announcement that CMS has decided to "freeze" Risk Adjustment fund transfers for an unknown period of time. Specifically:

“Our rate reduction would have been larger, but we had to account for added uncertainty in our rates due to indefinite suspension (the U.S. Centers for Medicare and Medicaid Services) placed on risk adjustment transfers between insurers,” said , said Mary Danielson, a BCBST spokeswoman. “Again, we were planning a larger reduction – around 18 percent – but needed to factor in the prospect of greater costs for 2019.”

Holy guacamole. I've noted repeatedly that unlike last fall, when average rate increases of 20-30% or more were commonplace for ACA individual market policies (due mainly to Trump cutting off CSR reimbursement payments), the preliminary rate requests for 2019 are actually averageing quite a bit lower than originally expected; of the 20 or so states I've crunched the numbers for so far, the weighted average for unsubsidized premium hikes is hovering around the 10% mark.

At first glance, it may sound like Democrats have been overplaying their hand when it comes to the "individual mandate repeal/short-term plan expansion is causing massive hikes!" attack. However, the rate increases from deliberate sabotage are happening...they're just being partly cancelled out by other factors, including:

Louise Norris has been saving me the trouble of digging up/writing up the approved rates in several states...

Insurance Commissioner approves rates insurers filed for 2018; Cost to cover CSRs has been added to silver plan premiums

On September 20, the Tennessee Department of Insurance and Commerce (TDIC) announced that the state had approved the rates that insurers had filed for 2018. However, the announcement indicated that Cigna’s approved average rate increase was 42.1 percent, which was based on the filing Cigna submitted in June 2017. An updated filing, with an average rate increase of 36.5 percent, was submitted in August, and TDIC confirmed by phone on September 21 that the updated filing was approved. The slightly smaller rate increase is due to Cigna’s decision to terminate some existing plans and replace them with new plans).

The following average rate increases were approved for 2018 individual market coverage:

This year, to the best of my estimates, Tennessee's total individual market consists of roughly 300,000 people, around 2/3 of whom are enrolled via the federal ACA exchange. Humana is dropping out of the state next year, meaning roughly 79,000 enrollees will have to shop around.

To my knowledge, there are actually 6 individual market carriers in Tennessee this year: Aetna, TRH (Tennessee Rural Health), Blue Cross Blue Shield, Cigna, Humana and "Freedom Life" (which, again, is basically a phantom carrier with no enrollees). Aetna and Humana are out, so that leaves TRH, BCBSTN and Cigna. TRH doesn't appear to have submitted an official 2018 rate filing as of yet, but they only had 3,500 enrollees this time last year anyway, so likely won't have much impact on the overall weighted average rate hikes.

Julie McPeak is the Tennessee Insurance Commissioner. She was appointed by a Republican Governor, Bill Haslam, and while the position itself appears to be nonpartisan, I've found several links indicating that yes, she's a Republican herself. This is hardly surprising in Tennessee, of course, and there's nothing wrong with it...but it's noteworthy given that Tennessee is among the 19 states which has been fairly hostile towards the ACA in general over the years (no state exchange, no Medicaid expansion, total GOP control and so forth).

I've noted repeatedly that while every year brings some amount of premium rate hikes and/or carriers dropping out of the exchanges (or off the entire individual market), there's a major new factor impacting both this time around: The Trump/GOP Sabotage/Uncertainty Factor. This includes, but isn't limited to:

Another very nice scoop by Sarah Kliff of Vox.com:

News: Tennessee’s empty shelf problem appears to be fixed! Blue Cross of TN will sell coverage in Knoxville area.

— Sarah Kliff (@sarahkliff) May 9, 2017

BCBS of TN says they’ll sell coverage in the 16 Eastern TN counties that had no carrier signed up for 2018. https://t.co/g3dkqU4G1m

— Sarah Kliff (@sarahkliff) May 9, 2017

Here's the full text of the letter; emphasis mine:

May 9, 2017

Dear Commissioner McPeak,

We appreciate getting to meet with you and your team yesterday to update you on BlueCross’s position relative to the individual Marketplace for Tennessee as the first deadline for 2018 approaches.

As most people know by now (well, most people in Tennessee, anyway), Humana decided a full two months ago to bail on the entire individual market, across the board--every state, both on and off the exchange, the works. This stung in quite a few counties across 11 different states, but the one which everyone is freaking out about is Tennessee...because there are 16 counties where Humana was the only carrier participating on the ACA exchange. Here's the list of Tennessee counties Humana is available in this year; note that there's an additional 14 counties where there's one other carrier available at the moment.

As noted a few weeks ago, Humana has already decided that regardless of what actions Donald Trump, Tom Price or Congressional Republicans end up doing (or not doing), they expect the 2018 individual market to be a big mess they want no part of...either on or off the exchanges:

...based on its initial analysis of data associated with the company’s healthcare exchange membership following the 2017 open enrollment period, Humana is seeing further signs of an unbalanced risk pool. Therefore, the company has decided that it cannot continue to offer this coverage for 2018. Through the remainder of 2017, Humana remains committed to serving its current members across 11 states where it offers Individual Commercial products. And, as it has done in the past, Humana will work closely with its state partners as it navigates this process.

Again, it's important to stress that Humana isn't just bailing on exchange participation, but to the best of my knowledge, they're pulling up stakes off-excahnge as well.

After their attempted merger with Aetna was roundly shot down by the federal government, insurance giant Humana issued a press release today with some major news:

Regarding the company’s individual commercial medical coverage (Individual Commercial), substantially all of which is offered on-exchange through the federal Marketplaces, Humana has worked over the past several years to address market and programmatic challenges in order to keep coverage options available wherever it could offer a viable product. This has included pursuing business changes, such as modifying networks, restructuring product offerings, reducing the company’s geographic footprint and increasing premiums.

As I noted when I crunched the numbers for Texas, it's actually easier to figure out how many people would lose coverage if the ACA is repealed in non-expansion states because you can't rip away healthcare coverage from someone who you never provided it to in the first place.

My standard methodology applies:

Normally I post screenshots from the revised/updated SERFF filings and/or updates at RateReview.HealthCare.Gov, but it takes forever and I think I've more than established my credibility on this sort of thing, so forgive me for not doing so here. Besides, #OE4 is approaching so rapidly now that this entire project will become moot soon enough, as people start actually shopping around and finding out just what their premium changes will be for 2017.

The other reason I'm not too concerned about documenting the latest batch of updates/additional data is because in the end none of it is making much of a difference to the larger national average anyway; no matter how the individual carrier rates jump around in various states, the overall, national weighted average still seems to hover right around the 25% level.

Still, for the record, here's the latest...in four states (Iowa, Indiana, Maine & Tennessee) I've just updated the requested and/or approved average increases. In the other four (Massachusetts, Montana, North & South Dakota) I've added the approved rate hikes as well.

Things are looking pretty good for the ACA exchanges in states like Rhode Island, North Dakota and Massachusetts, where they're looking at single-digit rate hikes next year. However, they're looking pretty dire in states like Arizona, Montana and Oklahoma, where the average hikes are likely to be around 50% or higher for many people.

And then there's Tennessee, where Blue Cross Blue Shield asked for and received a 62% rate hike...but even so, just announced that they're dropping out of the individual market completely (both on and off exchange) in 30 counties throughout the state, in the Memphis, Knoxville and Nashville areas:

Bluecross BlueShield of Tennessee is pulling out of three regions in 2017 for their individual/marketplace plans.

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