GRAHAM-CASSIDY REPEAL BILL DEADLINE:

Time: D H M S

Trumpcare

We're heading into the home stretch now, with the only remaining "supersize" state, FLORIDA. FL has the largest exchange-based individual market enrollment, and the 2nd largest total individual market enrollment of any state in the country, surpassing California for a variety of local economic/demographic reasons. The Kaiser Family Foundation estimates that FL carriers would have to add about 25% to their Silver plan premiums in order to make up for CSR reimbursements if Trump pulls the plug and/or Congress doesn't formally appropriate them. Since 80% of FL exchange enrollees are on Silver plans, that translates to roughly a 20% additional "Trump Tax" for the CSR factor alone. Note that while none of the carriers mention the CSR issue (meaning they all assume the payments will be made), Molina does call out the individual mandate enforcement issues as being part of their 37.5% rate increase request. Unfortunately, they don't put a hard number on this.

With Blue Cross Blue Shield of Nebraska declining to participate in the Nebraska exchange, that leaves just Medica as the sole individual market carrier. They're asking for a 16.9% average rate hike, 

Interestingly, while Medica's rate filing letter clearly states that the 16.9% request assumes CSR payments will be made and the mandate will be enforced, they also list "unprecedented uncertainty/risk inherent in the marketplace" as one of the key drivers of the increase.

The Kaiser Family Foundation estimates the CSR issue as adding around 15% to NE Silver plans, which translates into roughly a 10% additional increase if spread across all polices, or 26.9% overall.

There's only two carriers participating in Mississippi's individual market next year (plus Freedom Life, which once again is just a shell company here). They're asking for 16.1% average rate hikes, and since there's no mention in any of the filings about CSR payments not being made or the mandate not being enforced, I'm assuming that increase doesn't account for those factors.

The Kaiser Family Foundation estimates MS carriers would have to jack up Silver plans by a whopping 27% to cover lost CSR reimbursements. 87% of MS exchange enrollees receive CSR help, so that amounts to a stunning 23.5% average rate hike if spread across all individual policies. As a result, assuming they aren't made, I estimate Mississippi's average rate increase would be an ugly 39.6%.

Massachusetts has one of the stablest statewide insurance markets, no doubt in large part due to their having instituted the precursor to the ACA, "RomneyCare", 4 years earlier. Massachusetts also merged their small business and individual market risk pools, which helps stabilize things. As a result, they have a high number of carriers participating in their ACA exchange and are among the few states with single-digit average rate hikes...assuming CSR payments are forthcoming and the individual mandate is properly enforced.

Assuming CSR payments aren't made, I used the Kaiser Family Foundation's 19% average estimate for Silver plan hikes due to the CSR factor. Since a whopping 92% of MA's exchange enrollees chose Silver plans (it looks like MA's unique "ConnectorCare" plans are considered Silver as well), that means an average CSR factor of around 17.5 points across the entire individual market.

Louisiana has 3 individual market carriers for 2018 (technically there's 4, but "Freedom Life" is basically just a shell company with a placeholder filing). Officially, they're requesting average rate increases averaging around 21.4%...but all three carriers state point-blank in their filing letters that a huge chunk of their request is due specifically to the CSR reimbursement and mandate enforcement issues. The Kaiser Family Foundation estimates the CSR issue alone adds around 20 points to Silver plans, and 71% of Louisiana exchange enrollees chose Silver, so that translatest into roughly 14.2 points across the whole market. This results in just a 7.2% average rate hike if CSR payments are made vs. 21.4% if they aren't:

South Dakota is another fairly straightforward state: Two carriers, around 31,000 total ACA-compliant enrollees on & off exchange. Neither filing indicates whether they're assuming CSR payments will be made or not, so I'm assuming they're based on them being paid.

Another major state: Illinois. I've decided to scrap the "Low/High Increase" columns since they just confused people and made the table too wide, but replaced them with a new column showing the CSR factor estimate according to the Kaiser Family Foundation. Note that the percent listed will be smaller than Kaiser's estimate for each state, because their numbers only apply to silver plans, not all metal levels.

For instance in Illinois, Kaiser estimates that carriers would have to raise rates by 14% on Silver plans to cover their CSR losses. However, only 64% of Illinois exchange enrollees have silver plans to begin with, so I'm only plugging in about 9%. There are 5 carriers operating on the Illinois individual market (well, really 4, since "Freedom Life" doesn't count). I have the hard enrollment numbers for 4 of the 5; for Health Alliance Medical Plans I used 30,000 based on their 2016 number. Overall, Illinois is looking at around 11.3% w/partial sabotage, 20.3% with full sabotage:

Whew! OK, Texas was a bear for obvious reasons...13 different carriers (well, 12 really...Centene is new to their market). Several more are dropping out (Aetna, Allegian, Cigna, Humana, Memorial Hermann and Prominence), but suposedly theyonly have around 64,000 enrollees in TX combined. Texas's total individual market is actually closer to 1.6 million, so I'm obvoiusly missing a big chunk of enrollees below (and before my regular commenters say it: Yes, I'm sure the off-exchange TX indy market has shrunk this year, but I find it hard to believe it's shrunk by over 60% already).

Anyway, I've managed to plug in one hard request percent for each carrier--the FULL Trump Tax for 3 of them, the NO/PARTIAL Trump Tax for most. In Vista's case, they're off-exchange only so the CSR issue isn't a factor anyway. Unfortunately, I can't seem to find the enrollment number for Community Health Choice, so I don't know what their share of the market is, which could make a big difference if they have high enrollment. I've plugged in a flat 100,000 enrollees for the moment, but will change that if I'm able to track the actual number down.

Another fairly straightfoward state: Three carriers, two of which (CareFirst and Health Plan of Upper Ohio Valley) appear to be assuming CSR payments will be paid; the third, Highmark BCBS (which holds the vast bulk of the individual market) openly states that they assume they won't be made and that the mandate won't be enforced to boot. I'm once again assuming roughly 2/3 of Kaiser Family Foundation's "Silver CSR hike", which in this case would be about 10%, giving the following: 17.8% if CSR payments are made, 27.8% if they are:

Louise Norris gave me a heads up that the Kentucky Insurance Dept. has posted their 2018 rate hike filings as well. The individual market is pretty straightforward...and pretty grim: Both individual market carriers, CareSource and Anthem, are asking for pretty steep rate hikes even if CSR payments are locked in next year, averaging around 30.8%, while assuming another 13.5 points on top of that (71% of Kaiser's 19% Silver average) would bring the average up to around 44.3%. Not much else to say about this one for the moment.

The states filings are piling up quickly...Arkansas is pretty straightforward. Interestingly, four of the five carriers seem to be assuming that CSR payments will be made, and have submitted their rate filings accordingly; the fifth (and largest), USAble Mutual (aka Blue Cross Blue Shield of AR) is the only one to break it out specifically. In order to estimate the CSR factor for the other 4 carriers, I'm assuming 2/3 of Kaiser's 15% Silver plan bump estimate, or around 10 percentage points. That brings things in at around 10% even without CSR sabotage or nearly 18% with the CSR factor.

One other important thing to keep in mind regarding Arkansas: Their total individual market, including grandfathered and transitional plans, is something like 430,000 but they only have around 70,000 officially enrolled in ACA exchange policies. The main reason for this is that they have another 320,000 people enrolled in exchange policies via their "Private Medicaid Option"...which is Arkansas' version of ACA Medicaid expansion. For some reason, those folks aren't counted as ACA exchange enrollees even though it's my understanding that the only distinction between them and the 70K official enrollees is where the payments/subsidies come from.

In late May, I noted that Blue Cross Blue Shield of North Carolina, which holds a near monopoly on the individual market in NC with around 95% of total enrollment, had submitted an initial rate hike request for 2018 averageing 22.9% overall. What was remarkable at the time is that while most carriers were pussyfooting around using euphamisms about the reasons for their excessive increase requests, BCBSNC was among the first to come right out and state point-blank that it's the Trump Administration's deliberate sabotage of the market--primarily via the threats to cut off CSR payments and to not enforce the individual mandate--that are responsible for over 60% of the increase. This is from their blog, not mine:

Alabama, Alaska and Wyoming only have a single insurance carrier participating in each of their individual markets. While this is a bad thing from a competitiveness POV, it cetainly makes things easier for me from a tracking-average-rate-hikes POV.

ALSO IMPORTANT: The HHS Dept. is also starting to upload the rate filings to the official RateReview.Healthcare.Gov database, which should make things easier for me going forward (assuming that the data is uploaded properly and isn't messed with, which is a distinct possibility when it comes to the Trump Administration)

Officially, Alabama has the infamous "Freedom Life" phantom plan which is asking for a whopping 71.6% rate hike...to allegedly cover exactly one (1) person statewide. Un-huh.

Aside from that, however, it's Blue Cross Blue Shield across all three states...and they're asking for the following:

This isn't a full analysis, since I only have 2018 rate hike data for one of Arizona's carriers so far...on the other hand, AZ only has a couple of carriers on the individual market these days anyway. From AZCentral:

The Affordable Care Act insurer in 13 of Arizona's 15 counties plans to raise average rates across all plans a moderate 7.2 percent next year.

But Blue Cross Blue Shield of Arizona officials said the rate increases would be flat if President Donald Trump's administration did not plan to eliminate a key Affordable Care Act funding source.

7.2% isn't bad at all...of course, that comes after last years massive 57% average rate hike. Still, 0% would obviously be much better than 7%...

Trump suggested in a weekend tweet that " ... bailouts for insurance companies and bailouts for members of Congress will end very soon" unless Congress acts quickly on a new health bill.

Here it is...the Big Kahuna! Covered California just issued a detailed press release and accompanying PDF brochure breaking out their proposed 2018 market participation and rate changes:

Covered California Releases 2018 Rates: Continued Stability and Competition in the Face of National Uncertainty

Covered California remains stable, with an average weighted rate change of 12.5 percent. The change is lower than last year and includes a one-time increase of 2.8 percent due to the end of the health insurance tax “holiday.”

The competitive market allows consumers to limit the rate change to 3.3 percent if they switch to the lowest-cost plan in the same metal tier.

Pages