OE6

2018 MIDTERM ELECTION

Time: D H M S

Last summer, as part of his blatant and openly-declared attempt to undermine and sabotage the Affordable Care Act, Donald Trump's HHS Dept. slashed the marketing budget for HealthCare.Gov, the federal ACA exchange, by a whopping 90% (from $100 million to just $10 million), while also cutting the navigator/outreach budget by 41% (from $59 million down to $36 million). On top of this, they also proceeded to confuse the hell out of the grantees of those remaining funds by not providing any information or details before sending out the funds...and then changing their minds at the last minute in many cases and pulling the checks literally moments before they were supposed to be put in the mail. They also slashed the Open Enrollment Period itself in half while they were at it, from 3 months down to just 6 weeks.

For nearly a year, healthcare wonks like myself, David Anderson, Andrew Sprung and Louise Norris have been heavily getting the word out to promote not just the "Silver Loading" CSR-load workaround, but an even more clever variant which I've coined "the Silver Switcharoo" which takes the concept of Silver Loading and goes one step further.

It gets a bit complicated, but here's my explainer of how the Silver Switcharoo works for ACA individual market policies.

The bottom line is that in theory/on paper, just about everyone either comes out ahead or at least is no worse off if they use silver switching:

*(OK, these are technically only "semi-approved" rates...there could still be some additional tweaks later on after public comment, etc.)

Oregon was the fourth state which I ran a preliminary 2019 rate increase analysis on back in May. At the time, I concluded that insurance carriers were requesting a weighted average increase of 10.5% for ACA-compliant individual market policies next year. I knew that Oregon's state-based Reinsurance program was helping keep that average down to some degree, but I didn't know exactly how much of a factor it was.

I also knew that efforts to sabotage the ACA by Donald Trump and Congressional Republicans would play a major role in increasing 2019 rates: Repeal of the individual mandate is a big factor, along with the unnecessary 1-point increase in the state exchange fee being imposed on Oregon and the other four states which run their own exchange but "piggyback" on HealthCare.Gov's technology platform.

This article from KTVQ is excellent for my purposes. It clearly and cleanly plugs in just about all of the hard numbers I need to run my rate hike analysis: Which carriers are participating in the 2019 ACA individual market; how many current enrollees each carrier has (both on and off the exchange); and the exact average increase each one is requesting for next year!

Health insurers selling individual policies on the “Obamacare” marketplace in Montana are proposing only modest increases for 2019, on average – or, no increase at all.

State Insurance Commissioner Matt Rosendale released the proposed rates Thursday, with Blue Cross and Blue Shield of Montana proposing an average increase of zero – and a 4.9 percent decline for small-group policies.

The other two companies selling policies on the online marketplace, PacificSource and the Montana Health Co-op, proposed average increases of 6.2 percent and 10.6 percent for individual policies, respectively, and lesser increases for small-group policies.

 

Note: This is a follow-up to a post I wrote back in early May which was itself based on an earlier analysis by the folks at the Kaiser Family Foundation.

For weeks now, I've been painstakingly analyzing and plugging in the preliminary 2019 rate change data for ACA-compliant individual market as each state submits their filings. As of today, I've compiled data for 18 states (+DC), comprising perhaps 40% of the total ACA individual market, give or take. The table below shows where things stand at the moment.

Those yellow and manilla cells at the bottom are not a typo: To the best of my estimates so far, the insurance carriers across these 19 markets are asking for average 2019 unsubsidized premium rate increases of around 10-11%...however, as far as I can tell, they would be keeping rates FLAT year over year (on average), for the first time since the ACA launched, if not for three sabotage efforts by Donald Trump and Congressional Republicans: Repeal of the ACA's individual mandate, and Trump's removal of restrictions on non-ACA compliant "Short-Term, Limited Duration" and "Association" plans, which I've shorthanded as simply #ShortAssPlans....and in fact would actually be dropping in quite a few states (or, in the case of Minnesota, dropping more than they already are set to with those factors):

Florida is the 3rd largest state in the country, but has nearly the same number of ACA-compliant individual health insurance policy enrollees as California (around 2.0 million people if you subtract out grandfathered and transitional enrollees, vs. California's 2.1 million) even though Florida's total population is only 53% of California's (about 20.9 million vs. 39.5 million). Put another way, nearly 13% of Florida's non-elderly population is enrolled in the individual market, which is about twice as high as the natoinal average.

Add to this the fact that Florida is also the largest swing state politically, and people will be watching Florida's ACA exchange/premium situation very closely this fall.

Kentucky's 2019 preliminary Rate Filings have been posted, and they're pretty straightforward: Like this year, there will only be two carriers offering policies on the KY individual market in 2019: Anthem and CareSource, with roughly a 46/54 market share split.

The overall average requested rate increase is around 12.2% between the two. Neither carrier states just how much of their requested increase is due to mandate repeal or #ShortAssPlans (CareSource did list it...but then redacted it from public view). The Urban Institute projected around an 18.7 percentage point impact; 2/3 of that is around 12.5 points, so that's what I'm assuming until further notice.

Assuming that's accurate, that means that if not for the mandate/shortassplan sabotage factors, Kentucky carriers would be keeping unsubsidized 2019 premiums flat year over year (or even dropping them a smidge).

Hmmm...extremely thin detail here, but I'll take what I can get for the moment:

Ohio Health Insurance Exchange 2019

The Affordable Care Act (ACA) requires that every state have an exchange where consumers can buy individual health insurance policies. In Ohio, the federal government runs the health insurance exchange. Ohioans who do not have health insurance through their employer, Medicare or Medicaid may be eligible to purchase coverage through the exchange. Open enrollment for coverage next year (2019) begins November 1, 2018. Below is preliminary data based on the filings submissions of insurers in Ohio. Once filings are approved in late summer/early fall, final information will be posted.

Ohio’s Health Insurance Market (2018–2019)

In 2018, 8 companies sold health insurance products on the exchange in Ohio and 42 counties had just one insurer with an additional 20 counties having only two.

SEE UPDATE BELOW

WARNING: As far as I can figure, Texas's ACA-compliant individual market totals somewhere around 1.4 million people (Mark Farrah Associates estimated the entire individual market at 1.6 million a little over a year ago; of that I estimate roughly 180,000 were enrolled in grandfathered or transitional plans). The breakout as of today should be roughly 1.1 million on-exchange enrollees and perhaps 300,000 off-exchange.

Unfortunately, while the SERFF database shows 2019 listings for most of the 11 carriers which offer ACA policies in Texas this year, it only actually has the filings posted for 3 of them so far: CHRISTUS, Sendero and FirstCare Health Plans (aka SHA, LLC). Even then, those three carriers hold a pretty small share of the market, totalling just 65,000 enrollees. That means I only have actual 2019 rate data for about 5% of the ACA market available so far.

The Indiana Insurance Dept. has released the preliminary rate requests for 2019 insurance policies on the ACA individual and small group markets.

Like last year, there's only three carriers participating in Indiana's individual market: CareSource and Celtic (aka Ambetter) will again be available both on and off the ACA exchange, while Anthem will only be offering a single Catastrophic plan on the off-exchange market in just five counties:

The overall average rate increase for 2019 Indiana individual marketplace plans is 5.1%. CareSource and Celtic (MHS/Ambetter) have filed to participate in the 2019 Indiana Individual Marketplace. The Department of Insurance anticipates that all 92 counties in Indiana will be covered by one or more insurance company. CareSource plans to cover 79 counties. Celtic (MHS/Ambetter) plans to increase its coverage from 43 counties in 2018 to all 92 counties in 2019.

Anthem has filed to offer a 2019 Off-Marketplace plan in Indiana. This plan is a catastrophic plan and is offered only in Benton, Jasper, Newton, Warren and White Counties.

Well this is a nice surprise! Yesterday the Minnesota ACA exchange, MNsure, issued a press release a day ahead of the public posting of requested 2019 individual market insurance rate changes, advising people of the various ways they have to keep their premiums down via ACA tax credits, shopping around and so forth. I was immediately concerned that they might know something I didn't...perhaps they were expecting a batch of double-digit rate hikes as has happened in so many other states the past few years?

Well, today the Minnesota Commerce Dept. did release the preliminary 2019 rate requests, and I'm pleasantly surprised to report that for the second year in a row, Minnesota carriers are actually asking for rate decreases:

NOTE: I originally missed two carriers (McLaren and Molina); thanks to Louise Norris for calling attention to my error. The entire post, along with the table, has been updated to reflect the updated numbers including all 11 carriers.

Also note that while the headline originally reflected what the average rate change would be without the CSR load sabotage factor introduced in 2017, I've decided to be consistent with other states and only include 2018 sabotage impact.

My home state of Michigan just posted their preliminary requested rate changes for the 2019 Open Enrollment Period, and unlike most of the other states which have released their early requests so far, Michigan is a pleasant surprise: An overall average requested premium increase of just 1.7%!

Also noteworthy: According to the filings, eight of the carriers are specifically projecting exactly a 5% mandate repeal factor, which is remarkably consistent (usually the projections are all over the place). HAP is slightly lower (4.4%) while Molina is higher (7.2%). Priority Health didn't mention this at all, but it's safe to assume it'd be roughly 5% for them as well.

So, I just received the following press release from MNsure (Minnesota's ACA exchange)...

Tax Credits Through MNsure Can Help Lower Proposed Premiums for 2019
June 14, 2018

DULUTH, Minn.—Preliminary health insurance rates proposed by Minnesota health insurance companies will be available on the Minnesota Department of Commerce website on Friday, June 15.

Private insurance companies set premium prices, and the Minnesota Department of Commerce regulates those companies. Final, approved 2019 premium rates will be available by October 2, and the 2019 open enrollment period begins on November 1. Minnesotans shopping for health insurance through the individual market may be able to reduce premium costs in three ways:

1. See if you are eligible for tax credits only available through MNsure

As usual, Louise Norris has the skinny:

Rate filings were due in New Mexico by June 10, 2018, for insurers that wish to offer individual market plans in 2019. Insurers that offer on-exchange coverage have been instructed by the New Mexico Office of the Superintendent of Insurance (NMOSI) to add the cost of cost-sharing reductions (CSR) only to on-exchange silver plans and the identical versions of those plans offered off-exchange (different silver plans offered only off-exchange will not have the cost of CSR added to their premiums).

A couple of months ago, I sounded a (semi-muted) alarm about the future of Silver Loading and Silver Switching of Cost Sharing Reduction costs when CMS Administrator Seema Verma not only failed to state flat-out that she wouldn't attempt to stop these workarounds, but started giving indications that she was actively considering doing just that.

If this were to happen, then it would be devastating to millions of people while helping almost no one, as my colleagues Dave Anderson, Andrew Sprung, Louise Norris and I explained in Health Affairs a few weeks back.

Well, it appears that this particular bullet will be dodged for at least one year, anyway:

HHS won’t ban silver-loading this year, Azar admits after being pressed. No time to write broad-loading regs for 2019 plan year.

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