START OF 2018 OPEN ENROLLMENT PERIOD

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Sabotage

Up until a week ago, the possibility of Donald Trump pulling the plug on Cost Sharing Reduction reimbursement payments was a looming threat every day. While it hadn't actually happened yet, most of the state insurance commissioners and/or insurance carriers themselves saw the potential writing on the wall and priced their 2018 premiums accordingly (or at the very least prepared two different sets of rate filings to cover either contingency).

A few spread the extra CSR load across all policies, both on and off the exchange. This seems like the "fairest" way of handling things on the surface, but is actually the worst way to do so, because it hurts all unsubsidized enrollees no matter what they choose for 2018 and can even make things slightly worse for some subsidized enrollees in Gold or Platinum plans.

When I plugged in the requested rate hike numbers for New Jersey back in August, they averaged around 8.5% assuming CSR payments would be made, or around 21.6% if they aren't.

The approved rate increases for NJ were just released, and the numbers appear to be pretty close to that, if a bit higher: 9.9% and 22.0% respectively.

Truth be told, I only have the hard numbers for the exchange-based carriers...and even those aren't technically official; they come from this NJ.com article:

TRENTON -- New Jersey residents who bought their own health coverage from Horizon Blue Cross Blue Shield through the Affordable Care Act could pay an average of 24 percent more next year, according to state-approved rates released on Tuesday.

Horizon is one of three insurance companies in New Jersey participating in the Obamacare marketplace in 2018. But it is the most dominant, insuring 72 percent of the 244,000 individual policy holders this year.

I first looked at Rhode Island's proposed rate hikes back in early July. At the time, the average increase for the two carriers participating in RI's individual market was 10.5% assuming CSR reimbursement payments are guaranteed for 2018. If they weren't guaranteed, however, I estimated at the time that an additional 19 percentage points would be added into the mix, based on an estimate by the Kaiser Family Foundation.

However, I realized a little later on that I was misinterpreting KFF's analysis; they were referring to how much they estimated silver plans would go up due to the lost CSR funds, not all metal levels. Furthermore, for Medicaid expansion states (which includes Rhode Island) they estimated the average was only 15%.. Based on these factors, the impact across the board on Rhode Island should have only been around 10.3%.

Way back in May, Blue Cross Blue Shield of North Carolina submitted their initial 2018 rate requests to the state insurance department, and noted at the time that they'd normally only be requesting an 8.8% average rate increase...but that due specifically to Donald Trump's threat to cut off CSR reimbursement payments, they were asking for a 23.3% increase instead. I noted that this meant that about 60% of their increase request was caused by Trump's CSR threat.

Then, in August, they gave a somewhat more positive news update: They were lowering their requested rate hike to 14.1%. Basically, their latest numbers had come in and the balance sheet was doing quite a bit better than they had previously thought:

Blue Cross said May 25 that the 22.9 percent rate increase was based on the subsidies ending, along with claims data from the first quarter of 2017. It projected an 8.8 percent rate increase with the subsidies remaining in place.

 

OK, I was in on the Breaking News a few hours ago; unfortunately a) I had to pick my kid up from school and b) our power went out. (I'm currently online via our generator). As a result, I haven't actually posted anything here at the site about the just-announced Alexander-Murray deal until now.

Axios has the basics:

Sen. Lamar Alexander says he and Sen. Patty Murray have reached a deal to fund the Affordable Care Act's cost-sharing subsidies in exchange for giving states more regulatory flexibility with the law. Shortly after Alexander announced the deal to reporters, President Trump called it a "good short term solution."

OK, right off the bat: I guarantee you that Donald Trump (who just yesterday ranted about how "Obamacare is 'dead' and 'gone') doesn't have the slightest friggin' clue whether this (or any other deal) is "good" or "bad". He hasn't read it and he wouldn't understand any of it if he tried to anyway.

Press release from the North Dakota Insurance Dept,, September 28, 2017:

Medica Leaving North Dakota Individual Health Insurance Exchange in 2018
Post date: Sep 28, 2017

BISMARCK, N.D. – Insurance Commissioner Jon Godfread today confirmed that the Insurance Department was informed late Wednesday, Sept. 27, that Medica does not intend to sign an agreement with the federal government to offer coverage on the Affordable Care Act (ACA) Exchange for their individual health insurance in North Dakota for 2018.

“We have had numerous conversations with Medica over the course of the past few months, and given the uncertainty that currently exists around cost sharing reductions, they are unable to move forward in the Federal Exchange,” Godfread said.

Things were looking pretty dicey for two of Montana's three insurance carriers participating on the individual market the past few days. One of the three, Blue Cross Blue Shield, saw the writing on the wall regarding Cost Sharing Reductions (CSR) likely being cut off and filed a hefty 23% rate hike request with the state insurance department. The other two, however (PacificSource and the Montana Health Co-Op, one of a handful of ACA-created cooperatives stll around, assumed that the CSR payments would still be around next year and only filed single-digit rate increases.

I'm not going to speculate as to the reasons why they both did so when it was patently obvious that having the CSRs cut off was a distinct possibility, although I seem to recall the CEO of the Montana Co-Op said something about their hands being tied since CSR reimbursement payments are legally required, after all. Basically, it sounds like he was genuinely trying to avoid passing on any more additional costs to their enrollees than they had to.

Several healthcare wonk colleagues and I have been carefully piecing together the CSR sabotage price loading strategies for every state over the past week or so. This changed from a theoretical exercise to a real one due to Donald Trump officially pulling the plug on Cost Sharing Reimbursement payments effective immediately late Thursday night.

As in most states, the Michigan Dept. of Financial Services, seeing the potential writing on the wall, sent out a memo to all individual market insurance carriers instructing them to submit two different sets of rate filings for 2018: One assuming CSR payments would continue, the other assuming they won't:

Right on top of his potentially devastating executive order this morning (I haven't written up a formal post about it after the fact, but my explainer from a few days ago does a pretty good job of giving the gist), Donald Trump has supposedly finally decided to lower the boom for real on cutting off the legally and contractually mandated Cost Sharing Reduction reimbursement payments to insurance carriers:

President Donald Trump plans to cut off subsidy payments to insurers selling Obamacare coverage in his most aggressive move yet to undermine the health care law, according to two sources.

The subsidies, which are worth an estimated $7 billion this year and are paid out in monthly installments, may stop almost immediately since Congress hasn’t appropriated funding for the program.

UPDATE 10/13/17: Welp. Trump officially lowered the boom on cutting off CSR reimbursement payments last night, so CSR sabotage is no longer a threat, it's a reality (unless there's a court injunction or the GOP-held Congress actually gets off their asses and formally appropriates the payments with a simple, 87-word bill).

    Covered California (CA's ACA exchange) just issued the following press release:

    Covered California Keeps Premiums Stable by Adding Cost-Sharing Reduction Surcharge Only to Silver Plans to Limit Consumer Impact

    • In the absence of a federal commitment to continue funding cost-sharing reduction (CSR) reimbursements through the upcoming year, Covered California health insurance companies will add a surcharge to Silver-tier products in 2018.
    • However, because the surcharge will only be applied to Silver-tier plans, nearly four out of five consumers will see their premiums stay the same or decrease, since the amount of financial help they receive will also rise. Those who do not get financial help will not have to pay a surcharge.
    • Financial help means that in 2018, nearly 60 percent of subsidy-eligible enrollees will have access to Silver coverage for less than $100 per month — the same as it was in 2017 — and 74 percent can purchase Bronze coverage for less than $10 per month.
    • California and individual markets across the nation still need a clear commitment that the federal government will continue to make CSR payments to promote lower premiums, save taxpayer money and ensure health insurance companies participate.

     

    Joint post by David Anderson, Charles Gaba, Louise Norris and Andrew Sprung

    Note: This post is a joint effort with colleagues who have closely tracked the CSR chaos induced by Trump and Republicans in Congress. Dave Anderson is a former health insurance analyst, now a healthcare scholar at Duke, and a blogger at Balloon Juice; Louise Norris is co-owner with her husband Jay of a unique health insurance brokerage for individual market customers, and a top source of marketplace information and analysis at her own blog as well as at healthinsurance.org and elsewhere. Andrew Sprung writes about healthcare policy on his blog, xpostfactoid, as well as at healthinsurance.org and other publications.

    WARNING: THIS IS LONG AND WONKY BUT IMPORTANT.

    The Cost Sharing Reduction (CSR) payment controversy has been sucking up a huge amount of oxygen over the past 9 months. Most of this is due to Donald Trump repeatedly threatening to cut off the monthly reimbursements to insurance carriers since January, but some of the concern was already there before he even took office. Why? Because the whole reason the CSR payments are at risk of being discontinued in the first place is a federal lawsuit filed by John Boehner on behalf of the House Republican Caucus back in 2014.

    The case slowly ground it's way through the judicial process mostly under the radar for a couple of years. Law experts like Nicholas Bagley of the University of Michigan took the view that the case actually had some merit to it on the surface, but should still be shot down due to a lack of standing:

    *(OK, six, anyway)

    Here's something refreshing: U.S. Senator Angus King (I-ME) giving a floor speech in which he lays out at least a half a dozen different types of deliberate sabotage of the ACA's upcoming 2018 Open Enrollment Period by the Trump Administration to date. Start at 4:30:

    On Senate Floor, King Discusses “Sabotage” of the Affordable Care Act
    “Why does anyone want to have fewer people with insurance?”

    WASHINGTON, D.C. – U.S. Senator Angus King (I-Maine) today spoke on the floor of the U.S. Senate to address threats to the Affordable Care Act’s healthcare marketplace.

    “I’m rising today in sadness, but also in some anger because there’s a lot of talk about the Affordable Care Act collapsing,” said Senator King in his speech. “Mr. President, it is not collapsing – it’s being mugged. It’s being stabbed in the back. It’s being sabotaged, deliberately and consciously by the actions of the Administration. And I want to emphasize – this isn’t about ideology, it’s not about politics… this is about people.

    Earlier today, the Georgia Department of Insurance issued this press release:

    INSURANCE DEPARTMENT RELEASES PROPOSED RATES FOR 2018 HEALTHCARE EXCHANGE

    Atlanta – Insurance Commissioner Ralph Hudgens announced today that his office had submitted proposed 2018 health insurance rates to the Centers for Medicare and Medicaid Services (CMS) for the federally-facilitated Healthcare Exchange for final federal approval.

    “Today my office submitted 2018 Obamacare rates to Washington D.C. for approval,” Hudgens said. “In its fifth year, Obamacare has become even more unaffordable for Georgia’s middle class with potential premium increases up to 57.5 percent. I am disappointed by reports that the latest Obamacare repeal has stalled once again and urge Congress to take action to end this failed health insurance experiment.”

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