2022 OEP Week 4 HC.gov Snapshot Report: 3.0M enrollees total w/571K new

Hot off the presses, via the Centers for Medicare & Medicaid:

Week 4, November 21-November 27, 2021

In week four of the 2022 Open Enrollment Period, approximately 569,000 people selected individual market plans through the 33 states that use the HealthCare.gov platform. During the Open Enrollment Period, to date, approximately 3,004,000 people have selected individual market plans on HealthCare.gov. As in past years, enrollment weeks are measured Sunday through Saturday.

The final number of plan selections associated with enrollment activity during a reporting period may change due to plan modifications or cancellations. In addition, the weekly snapshot only reports new plan selections and active plan renewals and does not report the number of consumers who have paid premiums to effectuate their enrollment.

Approximately 2.8 million people newly gained access to affordable health care coverage during the 2021 Special Enrollment Period (SEP); 2.1 million who enrolled in the HealthCare.gov states for 2021, and 738,000 who enrolled in 2021 State-based Marketplaces ahead of the 2022 Open Enrollment Period.

For 2022 three states, Kentucky, Maine and New Mexico, transitioned to State-based Marketplaces (SBMs) for the 2022 Open Enrollment Period. These factors should be considered in any year-over-year HealthCare.gov enrollment comparisons. As in past years, the final Open Enrollment numbers, including SBM numbers, will be provided after Open Enrollment ends in all states.

One thing which is bothersome: In past years, CMS had started breaking the HC.gov total out by state by this point; for whatever reason, they haven't started doing so as of yet.

At first glance this looks like it's only 3.5% higher than last year's Week Four tally of 2,903,547 enrollees.

HOWEVER, there's two vitally important things to keep in mind:

First, last year's Week Two total included twenty-one days...whereas this year's only includes twenty (the Snapshot Reports run from Sunday - Saturday; last year November 1st happened to fall on a Sunday, this year it was on a Monday).

On a per-day basis, 2022 enrollment is actually up 7.3% over last year:

• OEP 2022: 111,256/day
• OEP 2021: 103,698/day

Secondly, as noted above, this year three states split off from HC.gov onto their own exchanges (Kentucky, Maine and New Mexico). Last year, 55,346 of the HC.gov enrollees in the first 3 weeks were from those three states, or 1.9% of them. When you remove those, the other 33 states on HC.gov only had 2,848,201 enrollees.

When you correct for that, 2022 HC.gov enrollment is actually up 9.4% vs. last year:

• OEP 2022: 111,256/day
• OEP 2021: 101,721/day

Also noteworthy is the number of new enrollees in the first three weeks: 571,115 so far this year vs. 659,455 last year. This is 13.4% lower...except that again, when you account for the missing day it's actually only 10.2% lower, and if you assume 1.9% of last year's new enrollees were from KY/ME/NM, it's only 8.4% lower year over year.

When you consider that many of the 2.03 million people who enrolled over the spring/summer via the COVID Special Enrollment Period in the 33 states now hosted via HealthCare.Gov likely would have been new enrollees had they not already done so, this is pretty remarkable.

It's also worth noting that active renewals (again, when adjusted for the missing day & states) are up 14.6% vs. last year:

• OEP 2022: 90,104/day
• OEP 2021: 78,623/day

This stat doesn't necessarily mean all that much (it could simply be people actively renewing sooner rather than later), but it does suggest that more people are beginning to understand the importance of actively re-enrolling instead of letting themselves be passively auto-renewed, which often means losing out on far better values and/or thousands of dollars in additional savings.

There's one more factor as well: Both Oklahoma and Missouri expanded Medicaid earlier this year (Oklahoma started in July; Missouri's state goverment was dragged into it kicking & screaming in October).

While most of the 275,000 Missouri residents & 190,000 Oklahomans who are eligible for Medicaid via ACA expansion weren't eligible for ACA exchange plans, a portion of them were (those earning between 100 - 138% of the Federal Poverty Level). I don't know exactly how many of those were actually enrolled in ACA plans prior to being shifted over to Medicaid, but according to the final 2021 OEP Public Use File report, nearly 150,000 of those who enrolled during the 2021 Open Enrollment Period earned between 100 - 150% FPL. Assuming around 85% of those earn 100 - 138% FPL, that suggests perhaps 125,000 who should be shifted over to Medicaid instead.

On the one hand, that doesn't take into account net attrition over the course of the year; on the other hand, it also doesn't include any of the 89,402 MO/OK residents who enrolled during the COVID SEP either (remember, while Oklahoma started their expansion program on schedule in July, which was halfway through the SEP, Missouri residents had no clue whether Medicaid would be expanded at all or not until after the SEP ended in mid-August). Assuming a similar ratio of all SEP enrollees were in the 100 - 150% FPL income bracket to the Open Enrollment Period, that means something like 28,000 additional 100 - 138% FPL enrollees will be shifted over to Medicaid as well.

Around 31% of all of Missouri & Oklahoma's 2021 OEP HC.gov enrollments happened in the first three weeks last year. If you assume a proportionate number of the 100 - 138% crowd signed up the first week, that's another ~39,000 who need who need to be discounted for an apples to apples comparison, which would mean 2022's first week is actually running 10.9% higher on a per-day basis. However, this gets a bit too speculative:

• OEP 2022: 111,256/day
• OEP 2021: 100,329/day

As an aside, 3.0 million total QHP selections is exactly what I was projecting yesterday based on Health Sherpa's weekly report.