2019 Rate Hikes

2018 MIDTERM ELECTION

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Monday afternoon there was a hell of a jaw-dropper out of the Empire State:

Gov. Cuomo just announced that he has directed Supt. Vullo to reject any individual market rate increase that included an increase to compensate for the repeal of the individual mandate

...Assuming that nothing else changes during the rate review process, this makes carriers that didn't associate a % of their rate request with the loss of the mandate big winners...and those who did, not so much.

Sure enough, after watching the half-hour speech by Cuomo, it sure as hell sounded like he was doing exactly that: Instructing the state insurance commissioner to only allow 2019 ACA individual market premiums to increase by around the 12.1% (on average) that they were expecting to go up with the ACA's individual mandate penalty in place instead of the roughly 24% (on average) that they said they'd have to raise them to cancel out the adverse selection impact of the mandate being repealed:

Hot on the heels of Wisconsin's ACA reinsurance program being approved by CMS comes another reinsurance waiver approval, this time for Maine:

The U.S Department of Health and Human Services and the U.S. Department of the Treasury (the Departments) approved Maine’s application for a State Innovation Waiver under section 1332 of the Patient Protection and Affordable Care Act (PPACA) (the waiver). Maine’s application seeks to reinstate a reinsurance program called the Maine Guaranteed Access Reinsurance Association (MGARA) from 2019 through 2023. As a result of the waiver approval, more consumers in Maine may have coverage, consumers will see lower premiums, and the state will receive Federal funds to cover a substantial portion of state costs for MGARA.

Maine’s State Innovation Waiver under section 1332 of the PPACA is approved subject to the state accepting the specific terms and conditions (STCs). This approval is effective for January 1, 2019 through December 31, 2023.

Summary of Maine’s State Innovation Waiver under section 1332 of the PPACA Application

Michael Capaldo is an employee benefits consultant and self-described "ACA wonk" out of New York.

I don't know him beyond some in-depth wonky online discussions, but I don't see any reason for him to make the following up:

Gov. Cuomo just announced that he has directed Supt. Vullo to reject any individual market rate increase that included an increase to compensate for the repeal of the individual mandate

— Michael Capaldo (@consultbenefits) July 30, 2018

Assuming that nothing else changes during the rate review process, this makes carriers that didn't associate a % of their rate request with the loss of the mandate big winners...and those who did, not so much.

— Michael Capaldo (@consultbenefits) July 30, 2018

January 2018:

It looks to me like after his short-lived 2016 Presidential campaign (seriously, it only lasted 70 days...heck, even Lincoln Chafee's campaign lasted twice as long), Wisconsin Governor Scott Walker decided to go back to shoring up his image in his home state...and since Wisconsin is one of 14 states which doesn't have any term limits for the top spot, it looks like he's scrambling to move back to the center policy-wise just in time to run for a third term this November:

Scott Walker proposes plan to prop up Obamacare marketplace

After years of fighting Obamacare, Gov. Scott Walker is now seeking to stabilize the state marketplace under the law.

This Just In from the Pennsylvania Insurance Dept...

Insurance Commissioner Highlights Minimal Rate Increases, More Consumer Choice in 2019 Health Insurance Rate Filings

Harrisburg, PA - Insurance Commissioner Jessica Altman today publicly released the 2019 requested rate filings for individual and small group health insurance plans under the Affordable Care Act, highlighting minimal rate increases and increased choices for many Pennsylvania consumers, including a new insurer in the individual market.

“Pennsylvanians want and deserve access to the comprehensive health coverage that the ACA provides. Enrollment over the past few years has remained steady, and this fall enrollees will have more choices, despite the Trump Administration’s relentless efforts to dismantle the ACA,” Gov. Tom Wolf said. “My administration is committed to ensuring that Pennsylvanians remain informed about their growing options and have access to quality, affordable health insurance.”

I noted a few weeks ago that the Oregon Division of Financial Regulation had issued their preliminary rulings on 2019 individual and small group market rate filings. At the time, they had whittled down the average requested indy market rate changes from 10.5% down to 7.8%, while leaving the requested small group rate changes the same (around 5-6% on average).

However, they also made sure to note that there was still one more round of reviews to go through before final, approved 2019 rate changes were locked in. Yesterday the OR DFR came out with those, making only slight further changes on the individual market (they bumped Kaiser up by 0.2 points while lowering Providence by 1.1 points). Providence has twice as many enrollees as Kaiser, so this resulted in an overall, weighted statewide average rate increase of 7.3%.

The final small group market rates were changed a bit more--Providence's increase was cut in half, while UnitedHealthcare's hike was cut by a couple of points.

This just in from the Connecticut Insurance Dept...

The Connecticut Insurance Department is reviewing 14 health insurance rate filings for the 2019 individual and small group markets. The filings were made by 10 health insurers for plans that currently cover about 293,000 people.

Two carriers – Anthem and ConnectiCare Benefits Inc. (CBI) – have filed rates for both individual and small group plans that will be marketed through Access Health CT, the state-sponsored health insurance exchange.

The 2019 proposed rate increases for both the individual and small group market are, on average lower, than last year:

California's contains over 12% of the entire U.S. population, around 13% of total ACA exchange enrollment and nearly 16% of the total ACA individual market. As such, when they make any announcements about their ACA exchange policies (or in this case, 2019 premiums), it's a pretty big deal for the national averages.

Today, Covered California, the largest state-based ACA exchange, announced their proposed 2019 ACA premium changes:

Covered California Releases 2019 Individual Market Rates: Average Rate Change Will Be 8.7 Percent, With Federal Policies Raising Costs

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.”

Breaking out of Nevada...

The cost of plans through Nevada’s health insurance exchange are anticipated to only increase by an average of 1.9 percent next year in what the state’s insurance commissioner said is the lowest proposed rate increase from insurance companies since the Affordable Care Act went into effect in 2014.

The announcement, made by the Division of Insurance late Tuesday morning, comes amid ongoing uncertainty about the impact that Congress’s repeal of the Affordable Care Act’s individual mandate and federal rule changes for two types of non-ACA-compliant health plans will have on the individual market as a whole. Insurance Commissioner Barbara Richardson cautioned that the proposed rates are subject to change based on any action by the federal government and said the division is working “diligently” to review the proposed rates from insurance companies.

That 1.9% figure is slightly misleading, though, because...

This year, thanks to their reinsurance program, ACA individual market premiums dropped by around 23.6% on average, from a whopping $1,040/month to "only" $795/month per enrollee.

HOWEVER, they would have dropped about 4.5 percentage points more if not for Trump cutting off Cost Sharing Reduction reimbursement payments, or roughly $560/year per enrollee. AK averaged around 16,000 effectuated ACA-compliant individual market enrollees per month in 2017, so that amounts to right around $8.9 million total. 6,930 enrollees qualify for CSR assistance this year, so that averages around $1,280 apiece in CSR help, which sounds about right to me.

Last fall I wrote a lot about how different states would be dealing with the tens of millions of dollars in losses they were facing after the Trump Administration decided to cut off Cost Sharing Reduction (CSR) reimbursement payments to them. As a quick reminder, there basically four (or five, depending on your POV) options available to each carrier and/or state insurance commissioner for dealign with CSR costs for 2018:

  • No Load: They could gamble that the CSR problem would be resolved and the payments would be made after all (i.e., they would price normally).
  • Broad Load: They could spread the CSR cost out evenly across all of their 2018 ACA policies, on exchange & off.
  • Silver Load: They could load the CSR costs onto all Silver plans only (both on & off exchange).
  • Silver Switcharoo: They could load CSR costs onto all on-exchange Silver plans only, while also creating "mirror" Silver plans off-exchange without any CSR load.
  • Mixed Load: Each insurance carrier could choose whichever of the other 4 strategies they wanted to and let the chips fall where they may. Not sure if this really counts as a "strategy", since it's more or less "all of the above".

Via the Colorado Division of Insurance:

DENVER (July 13, 2018) – The Colorado Division of Insurance, part of the Department of Regulatory Agencies (DORA), today released preliminary information for proposed health plans and premiums for 2019 for individuals and small groups. Colorado consumers can file formal comments on these plans through August 3.

2018 Companies Return for 2019
The same seven companies that offered on-exchange, individual plans are returning for 2019 - Anthem (as HMO Colorado), Bright Health, Cigna Health and Life, Denver Health Medical Plans, Friday Health Plans, Kaiser Foundation Health Plan of Colorado and Rocky Mountain HMO. And like in past years, this means that all counties in Colorado will have at least one on-exchange company selling individual health plans.

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:

Whew! Georgia only has 4 carriers participating in the individual market, but tracking down some of the data was a royal pain in the butt, especially Ambetter/Centene, which not only buried the numbers I needed inside a whopping 1,900-page PDF file, but the actual average requested rate increase wasn't even included; for that I had to check a different file. Yeesh.

The good news is that carriers in Georgia are only requesting around a 6.1% average rate increase for ACA-compliant individual market policies next year.

The bad news is that if it weren't for the ACA's individual mandate being repealed and the Trump Administration's expansion of #ShortAssPlans, 2019 premiums would likely be dropping by around 5.8% instead.

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