ShortAssPlans

 

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):

UPDATED 6/22/18: Added Indiana and Iowa to the table.
UPDATED 6/25/18: Added Florida, Kentucky, Ohio and Texas* to the table
*(Texas only has about 1/3 of the total ACA individual market accounted for, so it could easily change)
UPDATED 7/3/18: Added Montana and Georgia to the table
UPDATED 7/13/18: Added Tennessee, updated Texas to add BCBSTX
UPDATED 7/16/18: Added Colorado
UPDATED 7/17/18: Added Nevada
UPDATED 7/19/18: Added California
UPDATED 7/20/18: Added Connecticut

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.

Several quick tidbits out of the District of Columbia from the DC Health Benefit Exchange Authority May board meeting:

  • Their preliminary 2019 premium rate filings were originally due by May 1st, but this was bumped out until June 1st. Not available publicly yet, however.

*(OK, 95%+, anyway)

It isn't often that virtually everyone across the entire healthcare field agrees on anything, and yet here we are. Via Noam Levey of the L.A. Times:

Trump's new insurance rules are panned by nearly every healthcare group that submitted formal comments

More than 95% of healthcare groups that have commented on President Trump’s effort to weaken Obama-era health insurance rules criticized or outright opposed the proposals, according to a Times review of thousands of official comment letters filed with federal agencies.

The extraordinary one-sided outpouring came from more than 300 patient and consumer advocates, physician and nurse organizations and trade groups representing hospitals, clinics and health insurers across the country, the review found.

For a couple of months now, I've been attempting to track a slew of state-based "ACA 2.0" bills slowly winding their way through various state legislatures. However, this is really a bit of a misnomer, since some of these bills aren't so much about expanding the ACA as they are about protecting it from various types of undermining or sabotage from the Trump Administration and Congressional Republicans.

In fact, as far as I'm concerned, they really fall into three categories, which line up nicely with my color-coded "3-Legged Stool" metaphor: Blue, Green and Red Leg bills.

Once again: The "Blue Leg" of the Stool covers everything which ACA-compliant individual health insurance carriers are required to include: Guaranteed Issue, Community Rating, 10 Essential Health Benefits, a Minimum 60% Actuarial Value rating, no Annual or Lifetime Caps on coverage, and a long list of mandatory Preventative Services at no out-of-pocket cost when done in-network.

Just an hour or so ago I posted about a vice president of the Blue Cross Blue Shield Association stating point-blank what I and every other healthcare wonk under the sun has been warning for months (or years, really, if you include the original justification for the Individual Mandate under RomneyCare):

Kris Haltmeyer, a vice president at the Blue Cross Blue Shield Association, told reporters that the premium increases were in part due to the repeal of ObamaCare’s individual mandate in the Republican tax reform bill in December...“With the repeal of the individual mandate and the failure of Congress to enact stabilization legislation, we are expecting premiums to go up substantially,” Haltmeyer said.

...He said the premium increases are “related to the loss of the mandate and then underlying medical costs.”

“Those two things have the most impact on the rate increases,” he added.

...Oh, and what comes after mandate repeal and underlying medical costs? You guessed it: #ShortAssPlans

Two big developments (or in one case, a lack of development) out of Virginia this evening.

First: Just yesterday I was noting that it looked as though after 8 years, Virginia's state legislature might finally be going ahead and expanding Medicaid under the ACA as soon as today:

The stage is set for a showdown in the Virginia Senate on Tuesday over a budget compromise negotiated by Senate Finance Co-Chairman Emmett Hanger, R-Augusta, and House Appropriations Chairman Chris Jones, R-Suffolk, to expand the state’s Medicaid program and pay for the state’s share through a new tax on hospital revenues that also would boost Medicaid payments for inpatient provider care.

Unfortunately...that didn't happen:

Governor Northam Statement on Virginia Senate Budget Process

This evening brought three major pieces of ACA-related news out of three different states:

First, in California, the State Senate passed SB-910, which wouldn't just limit short-term plans, but would outright prohibit them altogether. To my knowledge, CA would be the only state* where STPs wouldn't be allowed at all:

(*Correction: It turns out that New York, New Jersey and Massachusetts also ban Short-Term Plans as well, although according to Dania Palanker of the Center on Health Insurance Reforms at Georgetown University, California would be the first state to explicitly outlaw short-term plans as opposed to simply stating that all policies have to meet certain standards.)

SACRAMENTO – Today, the State Senate approved passage of Senate Bill 910, which prohibits the sale of short term limited duration health insurance in California.

Having a doctor holding elected office is kind of hit or miss (former HHS Secretary Tom "Fly Me!" Price was an orthopedic surgeon, for instance, while Rand "Kneel before Aqua Buddha!" Paul is supposedly a "self-certified" opthamologist), but once in awhile it can be a very good thing.

Case in point: Ralph Northam, the new Governor of Virginia, a former Army doctor and pediatric neurologist, who just formally vetoed not one, not two, but four different GOP-passed healthcare bills, each of which would have further weakened and damaged the ACA individual market risk pool:

RICHMOND—Governor Ralph Northam today vetoed Senate Bills 844, 934, 935, and 964, which would put Virginians at risk of being underinsured, result in rapidly increasing Marketplace premiums, and undermine key protections in the Affordable Care Act. Governor Northam remains committed to expanding health care for nearly 400,000 uninsured Virginians, return millions to the state budget, and reduce Marketplace premiums. The Governor’s full veto statements are below.

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.

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.

Well, today, the other 2018 sabotage shoe dropped as the chief actuary for the HHS Department stated the obvious regarding Trump's #ShortAssPlans scheme:

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.

 

As promised, here's Part 2 of my Risk Pool explainer video!

Part 1 went over the basics of how risk pools work in general, and why segregating sick people into a separate pool is a terrible idea.

In Part 2, I go into more detail about the different types of NON-ACA plans available on the individual market, why they mostly stink, and how the repeal of the Individual Mandate Penalty, especially when combined with Trump's yanking away restrictions on "short-term" and "association" plans, will take an existing problem and make it far worse.

Oh, yeah: It involves Dabney Coleman and Morgan Freeman.

Aside from Virginia, it's likely going to be another month or so before the 2019 ACA policy rate filings start trickling in, since the deadline for initial rate requests isn't until late June in most states. However, there's some interesting non-ACA policy filing stuff which is available as well. Given all the concern about non-ACA compliant policies siphoning healthy people away from the ACA market, I figured I should take a look at a few of these.

Here in Michigan, I've found three such filings: One is for "transitional" plans from Golden Rule (a subsidiary of Unitedhealthcare, I believe). The other two are for "short-term" plans (the type which Donald Trump is basically removing any regulation on).

First up, Golden Rule:

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