OE6

2019 OPEN ENROLLMENT ENDS (most states)

Time: D H M S

Minnesota, currently entering their second year of their official reinsurance waiver program to help keep unsubsidized premiums down, announced their preliminary 2019 rate hikes way back in June. At the time, the carriers were looking at roughly an 8% average reduction in rates next year...although they would be dropping prices by more like 15% if not for the ACA's individual mandate being repealed and the expansion of #ShortAssPlans.

Today the Minnesota Dept. of Commerce posted the approved 2019 premium changes, and there's been some dramatic reductionsfor three of the five carriers offering policies in the state. Group Health and Medica were approved as is, but Blue Plus was told to drop their rates a whopping 27.7% instead of the 11.8% they were planning on. Ucare was shaved down from a 7 point reduction to 10 points, and PreferredOne (which only sells individual market policies off-exchange and only has 300 enrollees anyway) was knocked down from a 3-point reduction to 11 points.

The official annual ACA Open Enrollment Period (OEP) starting and ending dates have jumped around a lot since the exchanges kicked off back on October 1, 2013.

For the first OEP, people were given 6 months since the technology and the process were brand new to everyone...and thank God they were given the technical mess that the federal exchange (HealthCare.Gov) as well as many of the state-based exchanges experienced at launch. Things were eventually worked out, but not only was that extra time in spring 2014 vitally important, many people still needed some extra time beyond that as well. The official deadline to enroll for 2014 coverage was March 31, but the HHS Dept. gave people who had started their application by then an extra 15-day "overtime" period to complete the process.

For the 2015 OEP, the official dates were from November 15 - February 15th, cutting the time period down to three months. This time there was a one-week "overtime" period tacked onto the end.

For 2016 and 2017, HHS settled on November 1st - January 31st, which seemed to make sense since it was easier to remember: November, December, January.

I ran the numbers for Nevada's preliminary 2019 ACA individual market rate changes back in July. At the time, the average requested rate increase was around 2.3% statewide.

With the 2019 Open Enrollment Period coming up fast, I checked on the approved rate changes and found that state regulators had cut down on the rates quite a bit...although mostly for carriers which only offer off-exchange plans and only have small numbers of enrollees anyway.

For instance, HMO Colorado (dba HMO Nevada) originally requested a 20.9% increase; this was reduced to 9.5%...but they only have 200 people enrolled anyway, so it's not even a rounding error. Rocky Mountain was cut from 34.4% to 18.5%...but only has 300 enrollees, and so on.

The three carriers which hold the vast bulk of the market had far less dramatic changes, although Silver Summit was cut from a 5.2% increase to a 1.1% decrease for 2019.

eHealth Insurance is a leading private online health insurance exchange, and is licensed to sell health insurance in all 50 states and the District of Columbia. They also publicly post survey results of both their membership and insurance carriers from time to time. While eHealth isn't necessarily fully representative of the entire individual health insurance market, the fact that they cover every state +DC means their surveys should provide at least some big picture insight into the landscape.

(For those wondering: No, this is not an endorsement, they aren't paying me to promote them, and I haven't a clue whether or not they're a good or bad company to do business with.)

In any event, eHealth recently conducted an anonymous survey of health insurance companies operating in the Affordable Care Act market, asking about their plans for market participation in 2019. Insurers invited to participate in the survey are responsible collectively for insuring more than 200 million Americans. Here's some of their findings for what they're worth:

As I noted last month when I first analyzed the requested 2019 rates for North Dakota insurers, ND was somewhat unique last year in that it was one of only two states (the other was Vermont) which didn't tack on any extra premium increases for 2018 to account for the lost Cost Sharing Reduction reimbursement revenue after Donald Trump cut off those payments last October.

This led to one of North Dakota's three carriers, Medica, dropping off the ACA exchange altogether, though they still ended up enrolling a few hundred people directly via the off-exchange market.

As I noted back in July, in addition to the Trump Administration's Centers for Medicare & Medicaid (CMS) chopping down the marketing budget for HealthCare.Gov by 90% last year, they also slashed the navigator/personal outreach budget by over 40% as well, from $63 million down to $36 million...and this year have cut it by another $26 million, to just $10 million across all 34 states which rely on HealthCare.Gov to host their ACA exchange open enrollment functionality (there are 5 more states which are hosted by HC.gov, but which I believe operate their own exchange and navigator budget: Oregon, New Mexico, Nevada, Kentucky and Arkansas). Combined, that makes an 84% reduction in navigator funding over a 2 year period.

With the 2019 Open Enrollment Period rapidly approaching, I figured this might be a good time to remind everyone that while it starts on November 1st for most of the country, the largest state, California, is kicking things off 2 weeks early (17 days early, actually). Covered California is launching their 2019 ACA Open Enrollment Period on Monday, October 15th, 2018:

Open enrollment for 2019 coverage will begin October 15, 2018 in California, and continue until January 15, 2019

Nationwide, open enrollment for 2019 coverage is scheduled to run from November 1, 2018 to December 15, 2018 — the same schedule that was followed in late 2017 for 2018 coverage. But Covered California was one of only three state-run exchanges that opted in 2017 to keep open enrollment at three months in duration for 2018 coverage (the others were New York and DC).

And the state enacted legislation (A.B.156) in late 2017 that codifies a three-month open enrollment period going forward — California will not be switching to the November 1 – December 15 open enrollment window that other states will be using.

This is a pretty minor update, but I'm trying to lock in all of the approved 2019 rate changes as they come in. Last month, South Dakota's two carriers, Avera and Sanford, posted requested rate increases which I thought were 2.6% and 10.0% at the time. I also estimated their relative enrollment at around 27,000 and 4,000 enrollees apiece for market share calculations, which gave a statewide average increase of around 3.5%.

I checked the South Dakota Insurance Division website again today, and it certainly looks like the filings have been approved by the state insurance regulators...however, when I double-checked the filings themselves, it looks like they were actually slightly lower than I thought: 2.5% and 9.7% respectively.

In addition, I was able to find the hard enrollment numbers for each...the total is pretty close to what I had it at (29,180 vs. 31,000), but the splut is quite different. Insetad of Avera still having an 87% market share, it looks ike the split is more like 63/37 this year. Since Sanford is requesting a significantly higher increase than Avera, that means the weighted statewide average is higher as well...around 5.2% instead of 3.5%.

I posted Montana's preliminary/requested 2019 ACA indiividual market rate change requests back in late June. At the time, they were seeking average rate increases of 6.0% statewide, and I estimated that the GOP's repeal of the ACA's individual mandate penalty, combined with the Trump Administration's expansion of #ShortAssPlans, accounted for about 9.9 percentage points of that.

More recently, the state insurance commissioner's website published approved 2019 rate changes. The average increases have been sliced down slightly (from 6.0% to 5.7% on average), and I've lowered my estimate of #ACASabotage impact from 9.9% to 6% based on the lack of either factor being prominently mentioned in the actual carrier rate filings. If accurate that means rates would have been flat year over year on average in 2019 if not for those factors.

Unsubsidized Montana enrollees are paying an average of $637/month this year, so that's roughly a $38/month difference, or around $460 for the full year.

When Maryland insurance carriers originally submitted their proposed 2019 premium changes back in May, it looked pretty grim...they were expected to average around 29.5% statewide for the ACA-compliant individual market., increasing from around $631/month on average to roughly $817/month for unsubsidized enrollees.

Thanks to swift, bipartisan action on the part of the Democratically-controlled Maryland state legislature and the Republican Governor, Maryland was able to pass several bills which partially negated or cancelled out Trump/Congressional Republican sabotage of the Affordable Care Act. In particular, they passed laws which locked in current restrictions on both short-term plans and association health plans (the types of "junk policies" which Trump is pushing hard to expand upon)...along with an extremely robust reinsurance program.

 

Just in case anyone thinks state insurance regulatory boards can't be hard-core badasses, consider the Optima Health situation in Virginia which I wrote about a couple of weeks ago:

By early September, it was clear that Trump would indeed be cutting off CSR funding. With just a few weeks left before the final deadline to sign 2018 ACA exchange contracts, Optima suddenly announced that they were not only jacking up rates a whopping 81%, they were also pulling out of a large chunk of the state, leaving large areas at risk of "going bare" without any ACA carriers whatsoever.

...Then, on September 14, with just days to spare and thanks to what I assume were some pretty intense backroom deals being made, Anthem suddenly announced that they were back in the game after all!

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.

Way back on January 20, 2017, the very day Donald Trump was inaugurated, he issued an Executive Order which started the process of undermining the Affordable Care Act. As David Anderson of Balloon Juice succinctly put it:

yes individual mandate exemptions will be passed out like pacifiers at a rave

— David Anderson (@bjdickmayhew) January 21, 2017

section 2 is the meat. Defangs individual mandate by passing out hardship exemptions like candy on Halloween

— David Anderson (@bjdickmayhew) January 21, 2017

Iowa has only a single insurance carrier offering ACA-compliant individual market policies this year. Next year they'll have two, as Wellmark has decided to Hokey Pokey their way back onto the exchange again in 2019...but since they weren't around this year, there's no current policy premiums to measure any increase (or decrease) against.

That leaves Medica. Here's what they had to say about their 2019 rates back in June:

Medica, the sole carrier now selling individual health insurance policies in Iowa, plans to raise its 2019 premiums by less than a tenth as much as it did for 2018.

Medica raised its Iowa health insurance premiums by a staggering average of 57 percent for 2018. It was the steepest such health insurance increase in Iowa history. Company leaders said last summer they needed the higher premiums to stay in the market. But this time around, the Minnesota-based carrier is planning to raise Iowa premiums by an average of less than 5.6 percent, state regulators disclosed Wednesday.

 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:

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