UPDATE 6/8/18: Welp. Given last night's bombshell development that Donald Trump's Department of Justice has decided to not only abandon doing their jobs by defending the law of the land but to actually actively argue in favor of tearing away the ACA's prohibition of denying coverage for (or charging more for) pre-existing conditions, it seemed appropriate to dust off this entry from over a year ago.
A couple of important caveats: The individual market has shrunk by one or two milion people since a year ago (due in large part to other forms of Trump/GOP sabotage, I should note), so most of the estimates for the last column are likely a bit smaller as well, although those with pre-existing conditions are the least-likely to drop their coverae for that very reason. Also, a good half-dozen Congressional Districts have had special elections over the past year and now have new members of Congress (SC-05, MT-AL, PA-18 and so on) or currently have vacancies not shown below (MI-13, TX-27, etc).
At first it looked like CMS was planning on allowing doctors to "balance bill" Medicare patients. Balance billing is already a controversial issue with private insurance; it's the practice of a doctor/hospital charging the patient directly for the difference between what the doctor wants to be paid and what the insurance company agrees to pay them.
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).
Regular readers know that I've developed a tradition over the past three years of tracking the average unsubsidized premium rate increases for the ACA-compliant individual market, painstakingly poring over the rate filings for every carrier in every state and running a weighted average by their market share.
Every year there are numerous challenges and headaches which get in the way, including things as obvious as "not every carrier publishes the number of enrollees they have covered" to complex situations like "carrier X is dropping out of the on-exchange market in half the counties of the state but is sticking around in the off-exchange market". In addition, many carriers submit an initial rate request...followed a few months later by a revised one...neither of which might end up matching the final premium changes approved by state regulators. Sometimes there may be 2-3 more revised filings along the way which muddy the waters even further.
Back in June 2016, the Obama Administration rightly clamped down on "Short-Term Plans", limiting them to, you know, a "short term"...no more than 3 months out of the year, while also making them non-renewable; that is, you couldn't get around the 3-month limit by simply renewing the policy every three months:
An analysis of potential premium changes in states across the nation shows increases of 16 to 30 percent likely in 2019 if federal steps are not taken.
While the Patient Protection and Affordable Care Act’s subsidies would largely insulate subsidized consumers from these costs, millions of unsubsidized consumers would pay the full price of these increases. Many would likely be priced out of coverage.
Continued policy and premium uncertainty risks further carrier withdrawals, leaving more consumers with only one health plan and even the prospect of “bare counties.”
The analysis reviews three federal policy options that could stabilize markets and mitigate the impact of premium increases in many states.
Covered California’s open-enrollment period is still underway and consumers have through Jan. 31 to sign up for coverage.
A week or so ago, there was some confusing news about how Donald Trump may or may not be planning on signing a new healthcare-related executive order. I didn't write about it earlier because at first it sounded like he was talking about a meaningless "sell across state lines" decree...meaningless because the ACA already allows carriers to sell ACA-compliant policies across state lines, as long as the states in question sign onto an interstate compact.
It's not over yet, since the House of Representatives still has to vote on the bill again (either as is, or after hashing out the differences between the House and Senate versions of the bill), but assuming the final version of the bill includes mandate repeal and is indeed signed into law, this is what the ACA's 3-legged stool would look like when the dust settles.
Obviously I'll have much more to say about what happened last night soon, but for the moment I'll leave it at this.
Things were looking pretty dicey for two of Montana's three insurance carriers participating on the individual market the past few days. One of the three, Blue Cross Blue Shield, saw the writing on the wall regarding Cost Sharing Reductions (CSR) likely being cut off and filed a hefty 23% rate hike request with the state insurance department. The other two, however (PacificSource and the Montana Health Co-Op, one of a handful of ACA-created cooperatives stll around), assumed that the CSR payments would still be around next year and only filed single-digit rate increases.
I'm not going to speculate as to the reasons why they both did so when it was patently obvious that having the CSRs cut off was a distinct possibility, although I seem to recall the CEO of the Montana Co-Op said something about their hands being tied since CSR reimbursement payments are legally required, after all. Basically, it sounds like he was genuinely trying to avoid passing on any more additional costs to their enrollees than they had to.
Hey there, I called again and I was able to talk to a more knowledgeable agent who found out what the issue was and was able to enroll me in a plan!
Apparently, the Marketplace renewed automatically my application based on my 2016 income, which was enough to receive a tax credit in 2017, but is no longer enough to receive one in 2018.
Luckily, my income has increased since then, so I reported the change and was able to get a credit applied to the premiums
Still need to send copy of my green card for verification, but I can use the tax credit immediately
So I'm not sure why the person I talked to earlier today told me the rules had changed
Sorry for the confusion
OOF. OK, this pretty much torpedoes the entire basis of this blog entry. I'm going to leave it up in the interest of letting documented immigrants know that they ARE eligible to enroll AND for tax credits, but it sounds like the original concern may be unwarranted after all.
I've saved Texas for last because, frankly, I haven't been able to make heads or tails out of their actual average rate increases for next year (and unlike smaller states which might not move the needle on the national average anyway, Texas has one of the largest populations in the country, so a substantial error here can also impact the national numbers significantly).
Back in early August, I pieced together a rough average of the requested rate increases for the Lone Star State of around 20% if CSR payments are made or 32.5% if they aren't:
As noted earlier today, I've now managed to plug 48 states (plus DC) into my 2018 Rate Hike Project spreadsheet. This leaves just two states missing: New Hampshire and Texas. I'm still waiting to clarify some things for each, so this analysis could still change, but I really want to wrap this up, so here's what I have for New Hampshire right now:
When I first ran the numbers for New Hampshire'srequested 2018 rate increases, it seemed pretty straightforward: 3 carriers on the individual market. 2 listed rate changes assuming CSRs would be paid; one assumed they wouldn't. This gave the following: