Mandate Repeal

As I just noted earlier this afternoon, Massachusetts is NOT expecting the repeal of the ACA's individual mandate to impact their 2019 individual market enrollment or premiums for a simple reason: The Bay State never formally repealed their own, pre-ACA mandate penalty. They basically mothballed it once the ACA's version went into effect, and are simply dusting it off for 2019 and beyond now that the federal mandate has been formally repealed.

However, the two mandate penalties don't work quite the same way. For the federal mandate, unless you qualify for an exemption (and there's a whole bunch of those), the penalty for not having ACA-compliant healthcare coverage is (or has been up until now) as follows:

This Just In...

Ready for Open Enrollment, Health Connector sets 2019 plans with lower premium increases, selects community organizations to provide in-person support to residents

Boston – September 13, 2018 – The Massachusetts Health Connector Board of Directors today approved 57 Qualified Health Plans from nine carriers for individuals and families, with new plan designs that create better value for members and premium increases that average under 5 percent from 2018.

Unfortunately, the press release doesn't specify what "under 5%" means, nor does it break that out by carrier/market share. I've put in a request for those details and will update this as soon as I hear back from them. They sent me the following chart, but this only includes enrollees earning between 300-400% of the Federal Poverty Level, which means the marketshare across the entire individual market is likely somewhat different. I'm assuming the 4.4% overall average applies to the entire market but could be wrong about that as well:

For months now, I've been trying to get people to understand that when it comes to sabotage of the Affordable Care Act, especially in terms of individual market premium increases, you have to include the impact of actions taken by Donald Trump and Congressional Republicans in BOTH 2017 and 2018, not just 2018 alone.

In 2017, the single largest factor in the ~28% average national unsubsidized premium increase for ACA plans was Donald Trump's cutting off of Cost Sharing Reduction (CSR) reimbursement payments to carriers. This alone accounted for fully half of the 2018 increase. However, there were other, smaller actions taken which added up to another 3% or so: Slashing the Open Enrollment Period in half, CMS slashing the marketing budget for the federal exchange down 90%, slashing the outreach/navigator budget down 40% and so on.

 Back in June, Washington State delivered the bad news: They were expecting 2019 ACA-compliant premiums to increase by another 19.1% (due primarily to this year's sabotage of the law by Donald Trump and Congressional Republicans) on top of this year's 36% increase (10 points of which was due specifically to Trump's CSR reimbursement cut-off).

Today, Washington insurance commissioner Mike Kreidler announced the approved 2019 premium changes, and while the news certainly isn't great, it's not quite as bad as expected earlier this summer:

Hmmm...OK, this is rather curious.

New Mexico was one of the earlier states to post their initial, requested 2019 ACA individual market premium hikes back in June. At the time, the five carriers asked for rate increases ranging from a slight drop (-0.4% for Molina) to as high as an 18.5% increase for Presbyterian Health, which is currently only offering off-exchange policies this year. Based on their preliminary filings, New Mexico was looking at a weighted average increase of around 10.0% next year, which would have been more like 4% if not for this years sabotage efforts by Trump and the GOP (mandate repeal & expansion of #ShortAssPlans):

Normally at this point in the year I only do full rate hike write-ups for states when their approved rate changes are made public by insurance regulators. I'm making an exception for Texas, however, because my preliminary analysis of the statewide average premium changes back in June was missing a huge portion of the market--I only had around half the ACA individual market accounted for, and I repeatedly warned that the missing enrollment and rate change data could easily skew the statewide average higher or lower.

Well, it's early September now, and not only do I have access to pretty much all of the missing data now, some of the rate filings have changed significantly as well. At the time, I estimated Texas carriers as requesting average rate increases of just 1.5% overall, with them dropping around 10.6% if not for the ACA's individual mandate being repealed and Trump's expansion of #ShortAssPlans.

Back in April, I started an ambitious project which set out to track every legislative or regulatory measure taken by every state to counter, cancel out or mitigate sabotage of the Affordable Care Act by the Trump Administration and Congressional Republicans. It resulted in this color-coded spreadsheet, which lists dozens of bills, proposals, amendments and so on at various stages of completion.

The bad news is that project has proven to be too large for me to keep up with--there's simply too many bills, too many stages and too much other stuff going on for me to keep track of it all.

The good news is that the Center for American Progress (which has slightly more resources than I do) has launched their own version of this project, and it's very slickly done:

Hat tip to Louise Norris for the heads up about the Kentucky Dept. of Insurance issuing their final rulings for 2019 ACA individual market and small group policy premiums:

DOI Completes Review of Individual and Small-Group Health Insurance Rate Filings

The Kentucky Department of Insurance (DOI) announced today that it has completed its review of the individual and small-group insurance rates filed in the Kentucky market. The rates will be used to calculate insurance premiums in the 2019 benefit year.

Kentuckians in the individual market will once again experience changes in premiums and plan offerings. The rates that will be used reflect an average rate increase of 4.3 percent for Anthem Health Plans of Kentucky (Anthem) and 19.4 percent for CareSource. Since the actual premium charged will vary by individual and the plan level selected, some individuals may see a decrease in rates.

This just in from the Florida Office of Insurance Regulation...

OIR Announces 2019 PPACA Individual Market Health Insurance Plan Rates  

TALLAHASSEE, Fla. – The Florida Office of Insurance Regulation (OIR) announced today that premiums for Florida individual major medical plans in compliance with the federal Patient Protection & Affordable Care Act (PPACA) will increase an average of 5.2 percent beginning January 1, 2019. Per federal guidelines, a total of nine health insurance companies submitted rate filings for OIR’s review in June with final rate determinations due by August 22, 2018. 

Following OIR’s rate filing review, the average approved rate changes on the Exchange range from a low of -1.5 percent to a high of 9.8 percent. This information can be located in the Individual PPACA Market Monthly Premiums for Plan Year 2019 document available here.

When I first ran the preliminary 2019 ACA individual market rate filings for Virginia way back in May, I concluded that the average premium increase will be around 13.4%. However, a lot has changed since then.

For one thing, Virginia expanded Medicaid to 400,000 low-income residents, which should help improve the ACA risk pool and in turn knocked the average rate increase down by 2.2 points, to around 11.3%.

For another, Anthem made a last-minute decision to expand their coverage areas in the state dramatically, which also provides much-needed competition for Optima in the Charlottesville area, among others.

With the deadline for submitting 2019 rate filings having passed a week or so ago, the approved rates from the various state insurance regulators have been popping up left and right. Today I took a look at the Arkansas Insurance Dept. website and sure enough, they've posted the approved filings for all 4 carriers on the individual market (as well as the small group market).

On the one hand, the statewide average rate increase hasn't changed much from the preliminary average; it dropped 0.4 points from 4.5% to 4.1%...and some of that change is simply because I had misestimated the actual enrollment/market share for a couple of the carriers.

On the other hand, in Arkansas, at least, it appears that the carriers don't think the repeal of the individual mandate and/or the Trump Administration's expansion of short-term and association health plans will have nearly as big of an adverse selection impact as other estimates/projections have...including my own.

Busy day today! State insurance regulators around the country appear to have decided to start posting approved 2019 ACA rate filings all at once; within the past week, Vermont, Ohio, Delaware and North Carolina have posted theirs...and now you can add Georgia to the list:

The Obamacare rates for next year are in, and it’s a first: Rates are going down.

Following years of steep price hikes, two of the four companies that offer plans on the Affordable Care Act exchange in Georgia, also known as Obamacare, have proposed to lower their rates next year from what they charged in 2018.

According to figures for the individual insurance market released Thursday by the state Department of Insurance, Blue Cross Blue Shield of Georgia is proposing a tiny decrease in premiums for next year, with 2019 premium prices that are on average 0.3 percent lower than 2018’s premiums. Alliant Health Plans is decreasing its premiums by 10 percent.

North Carolina has three insurance carriers offering individual market policies next year: Blue Cross Blue Shield, which holds a whopping 96% of the individual market; Cigna, which holds the remaining 4%, and newcomer Ambetter (aka Centene).

I ran a write-up on BCBSNC's preliminary 2019 rate request at the end of July. While they're lowering their 2019 premiums by 4.1%, they also made it very clear that yes, they'd be lowering rates even further if not for the ACA's individual mandate penalty being repealed:

BLUE CROSS NC FILES TO LOWER ACA RATES BY AVERAGE OF 4.1 PERCENT

Durham, N.C. – Blue Cross and Blue Shield of North Carolina (Blue Cross NC) announced today it requested an overall average rate decrease of 4.1 percent for 2019 Affordable Care Act (ACA) plans offered to individuals. The reduction marks the first rate decrease in the history of Blue Cross NC since entering the current individual market more than 25 years ago.

...Many factors went into the Blue Cross NC’s rate filing:

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