2020 OPEN ENROLLMENT ENDS (most states)

Time: D H M S

Tennessee

via Becker's Hospital Review:

Cigna extended its individual healthcare exchange products for the 2020 plan year, the insurer said Sept. 18.

For 2020, individuals can purchase individual health plans in 19 markets across 10 states. The expansions will take place in counties in Kansas, South Florida, Utah, Tennessee and Virginia. The other states include Arizona, Colorado, Illinois and North Carolina.

The plans will be available for purchase on the individual marketplace during the 2020 open enrollment period, which begins Nov. 1. Plans will take effect Jan. 1.

via Bruce Japsen of Forbes:

MLR rebate payments for 2018 are being sent out to enrollees even as I type this. The data for 2018 MLR rebates won't be officially posted for another month or so, but I've managed to acquire it early, and after a lot of number-crunching the data, I've recompiled it into an easy-to-read format.

But that's not all! In addition to the actual 2018 MLR rebates, I've gone one step further and have taken an early crack at trying to figure out what 2019 MLR rebates might end up looking like next year (for the Individual Market only). In order to do this, I had to make several very large assumptions:

Last month I reported on Tennessee's preliminary 2020 premium rate filings. At the time, the weighted average rate change for ACA Individual Market policies was a 1.1% reduction over this year.

Today, the Tennessee Insurance Dept. officially approved the rate changes exactly as is, without making any changes one way or the other:

TDCI Approves Carriers’ 2020 Rates on the Federally Facilitated Marketplace
More Choices, Rate Decrease Highlight Rating Filing Season

The Tennessee Department of Commerce and Insurance (TDCI) announces the approval of insurance rates requested by the five carriers offering coverage on the Federally Facilitated Marketplace (FFM) in 2020.

via Brett Kelman of The Tennessean:

A new set of proposals provide some of the strongest evidence yet that Obamacare -- once on the verge of collapse in Tennessee -- has stabilized.

The state’s largest insurance company, BlueCross BlueShield of Tennessee, plans to reenter the Affordable Care Act marketplace in Nashville, Memphis and surrounding counties next year, providing another option for residents on Obamacare. Additionally, two other insurance companies that already offer Obamacare in these cities, Cigna and Oscar Health, are planning to significantly reduce the cost of their coverage plans.

Although the proposals are not final, it appears Tennesseans will have more options and competitive prices in the coming year, said Kevin Walters, a spokesman for the Department of Commerce and Insurance.

I'm lumping together three Tennessee-based stories here from the past month or so, but they're perfectly connected to each other:

March 7th, 2019:

The Tennessee House of Representatives passed a bill on Thursday that would ban abortion after a fetal heartbeat is detected, mimicking laws in other states that have been struck down by the courts and drawing the criticism of both advocates and opponents of abortion rights.

The measure, House Bill 77, would tightly restrict the window of time within which a woman could seek an abortion, because a fetal heartbeat can be detected as early as six weeks into a pregnancy. That is before many women even realize they are pregnant.

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.

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