END OF 2018 OPEN ENROLLMENT PERIOD (42 states)

Time: D H M S

Virginia

*(OK, Maine is a lock...except that GOP Gov. LePage is apparently still being an utter jackass about implementing it, while Virginia is still kind of iffy...see below...)

UPDATE 11/8/17: Maine voters approve Medicaid expansion

Maine voters on Tuesday decided to expand Medicaid to cover more low-income adults, becoming the first state to do so through a referendum.

Support for the ballot measure was up by more than 18 points with 64 percent of precincts reporting about 10 p.m. when it was called by NBC affiliate WCSH and The Associated Press.

The results in Maine, one of 19 states that rejected Medicaid expansion under the Affordable Care Act, comes as other Republican-led states like Utah and Idaho eye similar ballot measures.

Advocates of Medicaid expansion in Maine successfully petitioned the state to include a question on this year’s ballot following several failed legislative efforts to expand the program.

Up until a week ago, the possibility of Donald Trump pulling the plug on Cost Sharing Reduction reimbursement payments was a looming threat every day. While it hadn't actually happened yet, most of the state insurance commissioners and/or insurance carriers themselves saw the potential writing on the wall and priced their 2018 premiums accordingly (or at the very least prepared two different sets of rate filings to cover either contingency).

A few spread the extra CSR load across all policies, both on and off the exchange. This seems like the "fairest" way of handling things on the surface, but is actually the worst way to do so, because it hurts all unsubsidized enrollees no matter what they choose for 2018 and can even make things slightly worse for some subsidized enrollees in Gold or Platinum plans.

(sigh) When I last checked in on Virginia, things were looking up a bit (relatively speaking), as Anthem Blue Cross Blue Shield (aka "HealthKeepers") had announced that they were jumping back into the state in order to cover the 60-odd counties which would otherwise be left bare by Optima Health Insurance dropping out of half the state a week or so earlier.

Unfortunately, while this did resolve the "bare county" problem for VA, it didn't resolve the other big problem: Major rate hikes for unsubsidized individual market enrollees:

As many see their options for health plans dwindle down to one insurer, premiums are simultaneously set to rise by an average of 57.7 percent next year in Virginia’s individual marketplace.

The increase is “unquestionably the highest we’ve ever seen,” David Shea, health actuary with Virginia’s Bureau of Insurance, told lawmakers Monday.

August 11, 2017:

Anthem said Friday afternoon it planned to scale back statewide individual coverage in Virginia on the public exchange under the Affordable Care Act amid inaction by the Donald Trump White House on cost-sharing reduction subsidies.

Anthem, which operates under the Blue Cross and Blue Shield plan in 14 states, has already scaled back its Obamacare offerings in Indiana, Ohio and Wisconsin amid an unstable individual market for plans operating under the ACA.

“Today, planning and pricing for ACA-compliant health plans has become increasingly difficult due to a shrinking and deteriorating Individual market, as well as continual changes and uncertainty in federal operations, rules and guidance, including cost sharing reduction subsidies and the restoration of taxes on fully insured coverage,” Anthem said in a statement Friday afternoon. “As a result, the continued uncertainty makes it difficult for us to offer Individual health plans statewide in Virginia.”

Virginia was the very first state whose 2018 rate filings I analyzed, way back in early May. At the time, the initial filings amounted to 9 carriers on the individual market with an average rate increase request of around 30%. At the time I hadn't started distinguishing between "with CSR payments" or "without CSR payments", so I don't really know which scenario that 30% reflected; it was probably a mix of both depending on the carrier. 61,000 Aetna enrollees would have to shop around for a new carrier since they had previously announced they were pulling out of the individual market.

For the past two years, Virginia has been the first state in the nation to post their initial rate filings for the following year. I originally compiled their individual market 2018 change requests back in early May, and came up with the following at the time:

UnitedHealthcare had previously announced they were dropping out of Virginia, but I didn't have an enrollee number for them, and Aetna had also just announced their withdrawl from the state. I hadn't yet finalized my "CSR/Mandate Penalty" factor layout yet; at the time I assumed the 30.6% weighted average requested assumed full CSR/mandate sabotage and reduced that number by 17 points based on the Kaiser Family Foundation's "19% national average CSR rate hike" estimate analysis, which estimated the CSR impact at 17 points for Virginia.

UPDATE: As I've been warning for months, at least one of VA's carriers has openly stated that perhaps 40% of their requested rate hike is due specifically to concerns about the Trump administration & the GOP's ongoing sowing of confusion and outright sabotage of the ACA and the individual market.

A couple of weeks ago I noted that Virginia is one of the first states to post their initial premium rate hike filings. At the time, they hadn't posted the actual filings but at least listed the insurance carriers which were planning on participating in the individual and small group markets next year, both on and off the ACA exchange:

Last year Virginia was the first state out of the gate with their initial 2017 individual & small group market rate filings. I'm not sure if this is chance or if they simply have the earliest filing deadline. I'm guessing the latter, because, as Zach Tracer noted earlier today, Virginia is again the first state to list their 2018 Individual and Small Group Market participants. Remember, these are initial filings only, and very much subject to change throughout the summer and early fall. Here's who Tracer says has stated is committing to being on the ACA exchanges this fall...at the moment, anyway:

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:

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:

(sigh) OK, with three states still missing, you just knew I wouldn't rest until I was able to fill in the missing pieces of the puzzle. Sometime today, the HHS Dept. finally entered the approved rate hikes for individual makret carriers in two of those states: New Hampshire and Virginia. Louisiana is still AWOL for whatever reason.

It's important to note that sometimes the "Final Rate Increase" percentages listed at RateReview.HealthCare.Gov dont' actually end up matching the approved rate hikes found in the official SERFF databases or even at the state's Dept. of Insurance website. Normally I cross-check all three to make sure nothing weird is going on, but given that it's well past time to move on, I'm relying purely on the RateReview numbers for these states.

With that in mind, here's what it looks like in each:

Virginia was the very first state which I ran an estimated 2017 average requested rate hike for, way back in mid-April.

Since then, aside from Humana pulling out (leaving just 1,800 current enrollees to find a new policy), Virginia's ACA exchange market has actually been remarkably calm; the state somehow managed to escape the wrath of both UnitedHealthcare and Aetna relatively intact, with both carriers still participating in the state's exchange next year as of this writing.

There have, however, been a few other changes to some of the rate filings here and there, found via this updated PDF on the VA DOI website as of July 19th. The overall average requested hikes don't really change much, but do nudge a bit higher than I had previously estimated, from 17.5% to 18.4%:

This is really just a summary of my last 4 posts. I've combed through the SERFF databases for every state which uses the system for rate filings, and while very few have the actual 2017 rate filing requests listed yet, at least 4 of them have official individual market exit letters submitted for 2017 from Jane Rouse, the Product Compliance Process Owner for Humana Insurance Co:

This list may grow as additional state filing data and/or press releases come out from Humana, but assuming these are the only 4 states Humana is bailing on, the news isn't quite as bad as it appears at first.

To keep things in perspective, add the 4 numbers above up and it's 25,512 people across 4 states with a combined population of 21.8 million. Put another way, these 25.5K people represent only 2.9% of the 875,700 people Humana currently has enrolled in individual policies (both on & off exchange) nationally.

To be clear, I'm not saying this is a good development; when you combine it with the recent UnitedHealthcare Dropout Odometer it's more of a drip-drip-drip sort of thing. But it isn't disasterous for the exchanges either (at least not yet).

UPDATE: I've been informed by a reliable source that Humana is also dropping out of the individual market in Nevada next year, although I don't have any actual enrollment data there. Humana is not currently participating on the Nevada exchange, however, so any dropped enrollments would be OFF-exchange only. In fact, I'm pretty sure that the only individual market enrollees Humana has in Nevada are grandfathered policies anyway, so the numbers should be pretty nominal there.

I already noted last month that Humana is dropping out of Virginia's individual market next year, but since I'm in a "Humana pulling out!" mode this morning, I might as well post their official exit notice for completeness. Thankfully, the impact is nominal in Virginia, as only 1,800 people are being impacted total.

It's also worth noting that "grandfathered" enrollees only make up around 11% of Humana's total Virginia individual market as of this spring, which is somewhat higher than my overall ballpark estimate of around 1 million nationally.

 

So, yesterday I posted my first 2017 Weighted Average Rate Hike entry, using Virginia, since they appear to be the first state to post their requested rate changes for 2017.

As you can see, while the requested rate increases stayed consistent throughout the various updates, the number of enrollees changed dramatically depending on which filing source I used. Case in point: Anthem/HealthKeepers Inc.

The first filing I found for Anthem HealthKeepers made it pretty clear that they're asking for a 15.8% average rate hike next year which is expected to potentially impact up to 122,581 policy holders:

Pretty cut & dry, right? Note that according to the filing that number covers current Anthem HealthKeepers enrollees both on and off the exchange, so it should cover all ACA-compliant policies.

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