END OF 2018 OPEN ENROLLMENT PERIOD (42 states)

Time: D H M S

Charles Gaba's blog

Until today, I operated under the assumption that my home state of Michigan was among the 18 states which took the "Silver Load" approach to dealing with the Cost Sharing Reduction (CSR) cut-off by the Trump administration. Reviewing the SERFF rate filings of the various carriers participating in the individual market, it looked like most of them were loading the CSR cost onto both on and off-exchange Silver plans. I didn't check every single carrier, but that seemed to be the trend, so I filed the state under "Silver Load".

HOWEVER, earlier today, commenter "Cayo" chimed in to say:

I'm signing up for a plan off the exchange with Priority Health in Michigan. ON-Exchange, the plan is $365 a month, but off exchange (directly from their website), the price is $300 per month. I don't qualify for a subsidy, but it's still cheaper than my 2017 plan with BCBSM. That was the Multi-State Plan in Region 7 with Dental and Vision.

MAJOR UPDATE / MEA CULPA: 

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.

No one has been promoting the Silver Switcharoo option (in states which allow it) louder or more emphatically than I have for the past few weeks.

To summarize (again), this is where someone whose household income is too high for them to qualify for ACA tax credits (400% of the Federal Poverty Line) chooses an ACA-compliant off-exchange Silver plan instead, which is either identical or nearly identical to the same on-exchange policy in every way except that the additional CSR load hasn't been tacked onto it.

Here's a perfect example found by Louise Norris...ironically, this is via Priority Health here in Michigan, which (until today) I thought was a "Silver Load" state, not "Silver Switcharoo". I'll have to do some more research to be sure, but it sounds like at least one MI carrier (Priority) is going full Switch:

#1: The 2018 Open Enrollment Period is only half as long as usual in most states!

  • In the other 11 states (+DC), the deadline to enroll for 2018 coverage is later...but the final dates range from Dec. 22nd (CT) to as late as Jan. 31 (CA, DC & NY).

#2: BOTH types of Tax Credits/Subsidies ARE STILL AVAILABLE for those who qualify!

UPDATE: It looks like this issue may be limited to a single carrier in New Mexico; I've changed the headline and graphic accordingly...but it might be an issue in other states as well; if so I may have to change it back again...

Fantastic (if migraine-inducing) scoop by Susannah Luthi of Inside Health Policy (paywall):

Insurers That Filed Wrong Rates Told By CMS They Can't Sell Plans Through Mid-November

An issuer whose final CMS-approved rates don’t account for the loss of cost-sharing reduction payments is being told by the agency that they won’t be able to sell plans until healthcare.gov data is refreshed– even though this would mean the carriers are even more crunched for time to sell their plans during the shortened open enrollment period.

Last week I gave a very rough, back-of-the-envelope projection of perhaps 9.5 - 10.0 million Qualified Health Plan (QHP) selections during the 2018 Open Enrollment Period, which starts tomorrow. As I repeatedly emphasized, this wasn't based on any deep-in-the-weeds statistical analysis, because the one-two punch of the GOP's farcical "repeal/replace" efforts combined with the Trump Administration's "let Obamacare explode!" sabotage efforts have managed to botch things up so badly that I didn't see much point in expending the effort this year. Besides, others, such as Obama Administration Chief Marketing Officer Joshua Peck have already done part of this work for me:

Considering how absolutely obsessed the Trump Administration is about repealing the ACA, this new official report from Trump's Assistant Secretary for Planning and Evaluation (ASPE) seems like a strange way of showing it.

The very first bullet starts off ripping on the 37% average rate hike on benchmark Silver plans...

Benchmark Premiums: The average monthly premium for the second-lowest cost silver plan (SLCSP), also called the benchmark plan, for a 27-year-old increased by 37% from plan year 2017 (PY17) ($300) to PY18 ($411).

Premium Growth: For the first time, annual growth in the average monthly premium available to a 27- year-old for the SLCSP, at 37%, outpaced that of the lowest-cost plan (LCP), at 17%.

Of course, there's pretty obvious reason for that: Trump's cut-off of Cost Sharing Reduction (CSR) reimbursement payments. The ASPE report does go into this, but not until Page 6. Meanwhile, it's immediately undermined anyway (at least regarding subsidized enrollees) in the very next bullet:

With the 2018 Open Enrollment Period coming up just 5 days from now, it's time to put this to bed: After 6 months of painstaking research and analysis, I've compiled a comprehensive analysis of the weighted average rate changes for unsubsidized ACA-compliant individual market policies in 2018, including both the on- and off-exchange markets. It's already been confirmed by a different analysis by healthcare consulting firm Avalere Health, which used a completely different methodology to arrive at the exact same conclusion: The national average increase is between 29-30%, ranging from as low as a 22% average premium drop in Alaska (thanks to their successful reinsurance program) to as high as a painful 58% increase in Virginia.

And finally...

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's requested 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:

Cut 'n dry, right? Guess again: An August press release from the NH Dept. of Insurance stated:

With only 5 days to go before the launch of the 2018 Open Enrollment Period, time is rapidly running out for me to wrap up my 2018 Rate Hike Project. I started this, as I have for 3 years now, back in late early May with the very first requested rate changes out of Virginia, and have been tracking all 50 states as the summer and fall have passed, following every twist and turn of the insane repeal/replace circus in Congress, Trump's bloviating and blathering about "blowing things up" and "letting Obamacare explode", the last-ditch "Graham-Cassidy" sideshow and everything else, right up to and through Trump lowering the boom on cutting off CSR reimbursement payments.

When I last looked at Colorado's 2018 rate hike summary in early September, it appeared that they were looking at an overall average rate increase of either 33% or 41% without CSR reimbursement payments depending on your interpretation of a state DOI quote, or 26.7% assuming CSR payments are made. The confusion wasn't really cleared up much by the later announcement that Colorado is going with the "Broad Load" strategy for their "lost" CSR reimbursements.

Today I checked in with the Colorado DOI again, and they've posted the official, presumably final rate increases, assuming no CSR funding:

I'm still missing final 2018 rate data for 6 states, but in the meantime I'm also doing some cleanup of some of the states I thought I already had final data for. Today both my home state of Michigan as well as Washington State released their official, approved increase tables.

Michigan's average is nearly identical to what it was before...it only dropped from 26.9%...to 26.8%.

However, I do give the Michigan Dept. of Insurance & Financial Services huge credit for making it incredibly easy for me to plug their data in. Look at that...they list all carriers, whether they sell on or off exchange, the exact average rate increases, and even include the number of affected enrollees, which is usually the hardest number for me to track down. Thanks, MI DIFS!!

With 43 states accounted for, Open Enrollment itself looming just 6 days from now and HealthCare.Gov's window shopping tool now open for business anyway, there aren't likely to be too many surprises left for my 2018 Rate Hike project. For that matter, healthcare consulting firm Avalere Health just published their own analysis which confirms my own closely: They have the 2018 on exchange average increase at 29.1%, while I currently have the combined on & off-exchange average (for 43 states) at 29.2%.

Still, I don't like loose ends, and those 8 missing states are bugging me, so I still want to fill them in for completeness' sake. The only big state remaining is Texas, but I'm also missing Alabama, Hawaii, Iowa, Missouri, New Hampshire, Oklahoma and Wyoming.

As regular readers know, I've spent the third consecutive summer/fall painstakingly analyzing both the requested and approved unsubsidized (full-price) rate increases on the individual market for 2018. My track record the prior two years has been pretty good:

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