END OF 2018 OPEN ENROLLMENT PERIOD (42 states)

Time: D H M S

Trumpcare

Thanks to Zach Tracer for the heads up!

My 2018 Rate Hike project petered out a few weeks back with the requested rate increases posted for 46 out of 50 states (along with DC). Unfortunately, the last 4 states (Kansas, Missouri, Nevada and Utah) decided to keep their cards close to their chest, delaying any public viewing of even the requested rate increases for awhile longer.

Lori Lodes used to be Communications Director for the Centers for Medicare & Medicaid until last year under President Obama. As such, a big part of her job was administering ACA outreach efforts.

This evening, upon learning of the Trump administration's announcement that they're slashing advertising budget by 90% and outreach/navigation assistance funding by 39%, she was...not pleased. She took to Twitter to get a few things off her chest.

Instead of embedding a bunch of full Tweets, I'm pasting in the actual text of her thread to give the full picture:

Time to put on my "I used to run outreach for Obamacare" hat and talk about the Admin's decision to gut outreach and education.

***note*** This thread is long and barely touches on just how bad the impact of the Admin's decision will be.

First, it's the job of the government - in regs and everything - to educate people about signing up for health care.

Second, slashing navigator funding in a 3 yr cycle from $67m (2016) and $63m (2017) to $33m (2018) will mean that fewer people get covered.

via Sarah Kliff of Vox.com:

Trump is slashing Obamacare’s advertising budget by 90 percent

The White House will also cut the in-person outreach program by $23 million.

The Trump administration plans to deeply cut Obamacare outreach and advertising, officials announced Thursday.

Trump will reduce Obamacare advertising spending 90 percent, from the $100 million that Obama administration spent last year to $10 million this year. It will also cut the budget for the in-person enrollment program by 39 percent.

Administration officials cited “diminishing returns” from outreach activities. In a phone call with reporters, they said that most Americans already know about the Affordable Care Act.

As a reminder, here's what happened back in January, when Trump pulled the plug on advertising for HealthCare.Gov in the final, critical week of the 2017 Open Enrollment Period:

via Robert Pear, New York Times:

A Trump administration official said Wednesday that the administration wanted to stabilize health insurance markets, but refused to say if the government would promote enrollment this fall under the Affordable Care Act or pay for the activities of counselors who help people sign up for coverage.

The official also declined to say whether the administration would continue paying subsidies to insurance companies to compensate them for reducing deductibles and other out-of-pocket costs for low-income people. Without the subsidies, insurers say, they would sharply increase premiums.

The administration, the official suggested, will do the minimum necessary to comply with the law, which Mr. Trump has called “an absolute disaster” and threatened to let collapse.

When I last checked in on Maryland's individual market rate hikes for next year, the picture was pretty grim: Overall requested increases of around 46%...and that assumed that CSR reimbursements are made in 2018. If you assume CSRs aren't paid, it looked even worse: A whopping 57% average increase statewide for unsubsidized enrollees. Ouch.

Today, the Maryland Insurance Dept. issued their approved rate changes for the individual and small group markets...and while they did knock the rate increased down significantly, there's still not much to be cheery about. It also includes a couple of handy additional data points:

The Maryland Insurance Administration Approves Non-Medigap Premium Rates for 2018 Small Group and Individual Markets

Open Enrollment Begins Nov. 1 in the Individual Market; Consumers Encouraged to Shop Rates

Over at Balloon Juice, David Anderson has whipped up a nifty little graph which attempts to break out just which ACA exchange enrollees would be positively or negatively impacted by the CSR reimbursement brouhaha under different scenarios.

As I noted last month with my "Silver Switcharoo" explainer, for carriers which remain in the ACA exchanges next year, there's three potential scenarios which could happen (well, four, actually, if you include "Congress manages to sneak a full CSR appropriation bill into law just under the wire", although that seems pretty unlikely at this point given the time crunch and the fact that it'd need a 2/3 majority in both the House and Senate to avoid being vetoed by Trump anyway):

Back in early June, the New York Dept. of Financial Services posted the requested 2018 rate hikes for the individual and small group markets. In most states, the CSR reimbursement issue is a much bigger factor than whether or not the Trump Administration enforces the individual mandate, but in New York it's the exact opposite: According to the NY DFS, loss of CSR payments would only tack on 1.3 points to the total, while "a full repeal of the federal individual mandate would increase rates by an additional 32.6%".

The reason for the fairly nominal CSR factor is that the vast majority of NY's CSR-eligible population (those earning 138-200% FPL) is instead enrolled in the state's Basic Health Program. As a result, only 26% of New York's exchange enrollees receive CSR assistance, and the 200-250% FPL recipients only receive a fairly skimpy amount of CSR help anyway. At the opposite end of the spectrum, the 32-point mandate factor is far higher than most carriers are indicating (more like 4-5 points), but there's a big difference between the administration "not enforcing" the penalty and outright repealing it, which NY DFS is talking about.

In any event, this means that NY's requested average increases boiled down to: 15.0% if CSRs are paid/mandate enforced, 16.6% if CSRs aren't paid/mandate is enforced, or a whopping 50.5% if CSRs aren't paid and the mandate was repealed.

As I noted earlier today, there’s a gazillion ways the Trump Administration could sabotage (and in some cases, is already sabotaging) the 2018 Open Enrollment period this fall, doing everything in their power to dampen, obstruct and otherwise minimize the number of people who actually enroll in a healthcare policy via the federal ACA exchanges.

However, as I've noted before (and as the CBO confirmed last week), due to the confusing, inside out way in which the APTC and CSR subsidy formulas happen to work, there's also the potential for one of the most pressing sabotage schemes by Trump and the GOP to backfire completely, leading to the potential for a significant increase in ACA exchange enrollment.

I've noted before that even if the Trump Administration does ensure CSR reimbursement payments and does enforce the individual mandate in 2018, there are literally dozens of other ways that Trump and HHS Secretary Tom Price could sabotage the 2018 Open Enrollment Period. Here's just a few, several of which they've already been caught doing:

  • Minimal or non-existent advertising/outreach/promotional efforts
  • Understaffing of call centers/support staff, leading to absurdly long hold times
  • Deliberately underthrottled server bandwidth, slowing HC.gov down or even taking it offline, especially during peak hours
  • "Accidentally" misentered enrollment instructions or policy specifications
  • Confusing or missing confirmation/status notification messages either on the site, via email or both
  • Incorrect APTC/CSR subsidy formulas giving incorrect tax credit/financial assistance details to enrollees
  • Burying/completely removing the "Window Shopping" tool on the site

Here's another one for you, courtesy of Abby Goodnough of the New York Times:

For all the fuss and bother about how much premiums are expected to go up on a percentage basis next year, using percentages can be misleading, since the lower the premium is to begin with, the more dramatic a percentage increase is going to seem relative to where it started.

With that in mind, I've decided to mush together two recent projects of mine: First, my debunking/correction of the May ASPE report which disingenuously claimed that individual market premiums had "increased by 105% since 2013 due to the ACA"; second, my 2018 Rate Hike Project.

As I noted when I debunked/corrected the ASPE report, not only did it turn out to be somewhat lower when all 50 states were included (84%, not 105%), but the ASPE report completely ignores both the financial assistance provided to roughly half the market and, just as importantly, blows off the apples to oranges mismatch between the numbers, because only a handful of states had guaranteed issue laws in 2013, and only one (NY) had a community rating law. Having said that, as long as you keep those caveats in mind, the (corrected) ASPE report does provide a good baseline for figuring out what the 2018 premiums are likely to be.

By merging the spreadsheets for these projects together, I've come up with a rough idea of what I expect to see in terms of unsubsidized, full-price premiums for individual ACA policies this November. I'm using a median instead of a weighted average this time around because I expect high variables in terms of the number of people who enroll in each state compared to 2017 (unfortunately, I still don't have 2018 data for several states, and I don't have the 2017 dollar average for DC to compare against).

I've ordered the states from lowest to highest based on the assumption that CSR reimbursements aren't made next year ("full sabotage effect"). The blue sections are my best estimates for each state assuming CSRs are paid; the yellow sections represent how much of the average premiums are due to "CSR padding" by the carriers.

As noted in the Virginia and Maryland updates, I've started going through the earlier state rate filings and revising them to include:

  • Updated/revised carrier rate filings;
  • Additional market withdrawls and/or expansions;
  • Corrections to CSR factor impact, etc.

The original versions of each state writeup includes screen shots of the actual filing documents and explainers behind specific requests; I don't have time for that with most of the updates, so I'm bundling several states together. Here's Connecticut, Oregon and Vermont's revisions:

As noted the other day, now that I've compiled the initial 2018 rate filing requests for 46 states + DC (the remaining 4 states aren't public yet), it's time to go back to the earlier states I analyzed and see whether there's been any updates/corrections to my original estimates. I started running the numbers back in early May, and a lot has changed since then, with carriers dropping out of the exchanges, expanding to fill the gaps or simply refiling with revised pricing requests.

Maryland was the second state I analyzed; I originally came up with the following average:

For the past two years, Virginia has been the first state in the nation to post their initial rate filings for the following year. I originally compiled their individual market 2018 change requests back in early May, and came up with the following at the time:

UnitedHealthcare had previously announced they were dropping out of Virginia, but I didn't have an enrollee number for them, and Aetna had also just announced their withdrawl from the state. I hadn't yet finalized my "CSR/Mandate Penalty" factor layout yet; at the time I assumed the 30.6% weighted average requested assumed full CSR/mandate sabotage and reduced that number by 17 points based on the Kaiser Family Foundation's "19% national average CSR rate hike" estimate analysis, which estimated the CSR impact at 17 points for Virginia.

Regular readers know that I've spent the past 4 months painstakingly tracking and analyzing the 2018 individual market rate filings for pretty much every insurance carrier in every state across the country.

I've completed this process for 46 states + DC. I've confirmed (well, really, Louise Norris confirmed for me) that the filing data for the four missing states--Kansas, Missouri, Nevada and Utah--won't be made available publicly for another couple of weeks, which is irritating...but those four states combined only make up about 5% of the total population anyway; unless their average rate increase requests are significantly higher (or lower) than the average of the rest of the states, they aren't gonna move the needle up or down by more than a tenth of a point or so.

Like Wisconsin and Michigan, Ohio has a high number of carriers statewide...although the per-county competition is still lacking in some areas. Even so, their rate hike requests are still pretty high even with CSR payments being made...and dramatically higher if they aren't.

One interesting tidbit: Check out the CareSource filing letter (first one below the table). They don't mention CSRs or mandate enforcement...but they do specify that a full 5 points of their 23.9% increase request is tied to prescription drug inflation (see Shkreli, Martin)...and even more noteworthy, they say that another 5 points is due specifically to "a number of previously [Medicaid-] qualified individuals" being kicked over to the private exchange, 

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