I've written quite a few entries bashing the Short-Term Plan portion of Donald Trump's executive order opening up the floodgates on non-ACA compliant policies. However, I've written far less about the other shoe he's dropping: Association Health Plans, or AHPs. In fact, while I discussed AHPs briefly in Part Two of my Risk Pool video, the only blog post I've written to date which specifically focuses on them just quoted from this Avalere Health article:
Association Health Plans (AHPs) are health insurance arrangements sponsored by an industry, trade, or professional association that provide health coverage to their members—typically small businesses and their employees. Health insurance coverage offered through AHPs aims to make coverage available and affordable for small groups and individual employees. Importantly, these arrangements are currently governed by state and federal requirements and are subject to state oversight, including standards related to premiums and benefit requirements.
Polls in 6 Battleground States Show Voters Blame Republicans for Rate Hikes
Six new Public Policy Polling surveys in battleground states find voters will blame Republicans for the expected health care premium increases this summer by approximately 30 points and voters believe Republicans and President Trump have been actively undermining and sabotaging the Affordable Care Act.
ARIZONA Voters say they will blame Republicans if health care premiums increase this summer. 55% say they will hold Republicans in Washington responsible if rates increase, compared to just 29% who said they would not. A plurality of voters (49%) say they believe Washington Republicans and President Trump have been trying to undermine and sabotage the Affordable Care Act – and a majority of independent voters (57%) also say they agree with that statement.
OK, this doesn't technically count as an official 2019 Rate Hike analysis since none of it comes from actual carrier rate filings, but Covered California, the largest state-based ACA exchange, just released their proposed 2018-2019 annual budget, and it includes detailed projections regarding expected premium increases and enrollment impact over the next few years due specifically to the GOP's repeal of the ACA's Individual Mandate. Oddly, while they mention short-term plan expansion as another potential threat to enrollment/premiums, they do so passingly, and they don't mention association plans at all:
Since 2014, nearly 5 million people have enrolled in Medi-Cal due to the Affordable Care Act expansion, and more than 3.5 million have been insured for some period of time through Covered California. Together, the gains cut the rate of the uninsured in California from 17 percent in 2013 to a historic low of 6.8 percent as of June 2017.
Last month, after much painstaking research and analysis, I concluded that unsubsidized ACA-compliant individual market enrollees (both on & off the exchanges) are paying an average of around $960 this year (~$80/month) more in healthcare premiums nationally in 2018 than they otherwise would be if not for the various forms of ACA sabotage carried out by Donald Trump and Congressional Republicans last year.
Again, it's important to clarify that this is $960 more (around 17% more) in addition to non-sabotage-related factors such as normal medical expense inflation (around 7%), the reinstatement of the ACA carrier tax (about 2%) and other various/sundry factors (around 2%).
Back in mid-April, I crunched a bunch of numbers and concluded that around 6.5 million people enrolled in unsubsidized ACA-compliant individual market policies are, on average, paying an additional $960/year ($80/month) for their policies this year due specifically to last year's sabotage efforts by Donald Trump and Congressional Republicans. This is separate from other factors such as medical trend and the reinstatement of the ACA carrier tax. The actual 2018 "Trump Tax" ranges from as little as almost nothing at all in Vermont and North Dakota to as high as $1,500 per enrollee in Mississippi and Pennsylvania.
The 2018 sabotage impact was mainly due to 1) CSR reimbursement funding being cut off; 2) uncertainty over individual mandate enforcement; and 3) a mish-mash of Open Enrollment changes including cutting the time window in half, slashing marketing/assistance budgets by 90% and 40% respectively and so forth.
The Kaiser Family Foundation just released an important new study which proves everything I've been saying for the past year and a half: After years of turmoil, the ACA-compliant individual market had finally quieted down and reached equilibrium last year...right up until Donald Trump, combined with total GOP control of the federal government, deliberately came in like a wrecking ball and messed everything up again:
Concerns about the stability of the individual insurance market under the Affordable Care Act (ACA) have been raised in the past year following exits of several insurers from the exchange markets for 2017, and again last year during the debate over repeal of the health law.
A couple of weeks ago, Donald Trump's former HHS Secretary Tom Price openly (and rather casually) admitted at the World Health Care Conference that the GOP's repeal of the ACA's individual mandate will "harm the pool in the exchange markets & drive up costs" when it actually goes into effect in 2019.
WASHINGTON — President Trump’s plan to expand access to skimpy short-term health insurance policies, as an alternative to the Affordable Care Act, would affect more people and cost the government more money than the administration estimated, an independent federal study says.
Normally, I don't start posting natoinal projections for my annual Rate Hike Project until I have at least filing data for at least a dozen or so states because the national weighted average jumps around so much early on. A "national average" of, say, 10% based on numbers from, say, Vermont, Wyoming and the District of Columbia (collective population: 1.9 million people) is gonna change radically once you add California or Florida to the mix if they're looking at a 20% hike, for example.
Having said that, seeing how advocacy organization Protect Our Care has decided to launch their own version of my Rate Hike Project, and seeing how I do have preliminary 2019 rate increase projections from at one large state (Virginia) and two mid-sized states (Maryland and Oregon), I've decided to go ahead and start posting the national projections early, with a major caveat that the national average will likely change dramatically until at least 2/3 of the states have been plugged in.
For three years now, I've been painstakingly tracking the annual average rate increases for ACA-compliant individual market policies across all 50 states (+DC) and nationally, including both the on & off-exchange markets in as much detail as possible, and at the risk of tooting my own horn too much, my track record on this has been pretty damned accurate:
Implications Of CMS Mandating A Broad Load Of CSR Costs
In October 2017, the Trump administration eliminated federal funding to reimburse insurers for cost-sharing reduction (CSR) subsidies, which they are obligated to provide to qualifying enrollees in the Affordable Care Act (ACA) Marketplace. President Donald Trump had threatened to eliminate CSR funding throughout 2017, so insurers and insurance regulators in many states had anticipated the move by adding the cost of CSRs to premiums for 2018.
Insurers selling Obamacare plans in Maryland are again seeking huge rate increases for 2019, but they could be knocked down significantly by a reinsurance program the state hopes to implement for next year.
CareFirst BlueCross BlueShield wants to increase rates on average by 18.5 percent on its HMO plans, which account for more than half of the individual market this year.Kaiser Permanente, the only other insurer selling on the exchange, is seeking a 37.4 percent average increase on its HMO plans, which cover just over a third of Obamacare customers.
A couple of days ago, I posted that Virginia has become the first state out of the gate with their preliminary 2019 premium rate requests for ACA individual policies. However, I made sure to emphasize that these are preliminary requests only; carriers often resubmit their rate change requests more than once over the course of the summer/fall, and even that may not match whatever the final, approved rate changes are by the state insurance commissioner.
In addition, I generally try to make it understood that there's alotof room for error here--the weighted averages are based on the number of current enrollees, but of course that number can change from month to month as people drop policies or sign up during the off-season (via Special Enrollment Periods). Even then, the rate filing paperwork is often vague or confusing about just how many enrollees they actually have in these plans. Sometimes wonks are reduced to taking the number of "member months" and dividing by 12 to get a rough idea of how many people are enrolled in any given month. Sometimes the only number of enrollees available are from last year, which could bear zero resemblence to how many are currently enrolled. Sometimes the only number available is how many people the carrier expects to enroll in their policies next year. And so on.
IMORTANT UPDATE: As I suspected, it turns out that the stray rate filing posted to the California Insurance Dept. website a few days ago was posted prematurely, doesn't reflect the carrier's final* rate filing, and has since been pulled from the California Insurance Dept. website.
I've been asked to remove the filing data, and seeing how there's nothing nefarious about it (I wasn't "whistleblowing" evidence of anything criminal/unethical), I'm complying with that request. Since everything in the post related to that data, there wasn't much point in keeping the rest of it either.
*(Yes, I'm aware that none of these early filings are "final" since they tend to be revised/resubmitted throughout the summer/fall, but you know what I mean.)
...and to absolutely no one's surprise, GOP sabotage of the ACA will be directly responsible for a significant chunk of the individual market premium increases.
Every year for 3 years running, I've spent the entire spring/summer/early fall painstakingly tracking every insurance carrier rate filing for the following year to determine just how much average insurance policy premiums on the individual market are going to increase (or, in a few rare instances, actually decrease).
The actual work is difficult due to the ever-changing landscape as carriers jump in and out of the market, their tendency repeatedly revise their requests, and the confusing blizzard of actual filing forms which sometimes make it easy to find the specific data I need and sometimes make it next to impossible.