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.
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.
The effort was spearheaded by Republican John "Yeah, he's definitely primarying Trump in 2020" Kasich of Ohio and Democrat John Hickenlooper of Colorado, but also includes Brian Sandoval (GOP, NV); Tom Wolf (Dem, PA); Bill Walker (Indy, AK); Terry McAuliffe (Dem, VA); John Bel Edwards (Dem, LA); and Steve Bullock (Dem, MT).
Here's a partial version of the letter with the meat of the asks:
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.
State officials increasingly worry that this year’s turbulent health-care politics could threaten funding for the Children’s Health Insurance Program, a popular initiative that usually wins broad bipartisan support.
Federal funding for CHIP is set to end Sept. 30. The federal-state program provides health coverage to more than eight million low-income, uninsured children whose family incomes are too high to qualify for Medicaid.
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.
As health care debate simmers, Mead laments lack of Medicaid expansion in Wyoming
Gov. Matt Mead lamented the $100 million that Wyoming left on the table by choosing not to expand Medicaid, and he expressed concern for the state’s hospitals while discussing health care with the Star-Tribune recently.
Mead echoed some of the fears that many Wyoming hospital officials have expressed for months: that congressional proposals to overhaul the health care system may have negative effects on facilities here and that the state has suffered because it chose not to allow more people to qualify for Medicaid.
“The idea that we did not accept Medicaid expansion and things are going to be good just hasn’t turned out,” he said.
The following letter was just sent to GOP U.S. Senator Lamar Alexander and Dem U.S. Senator Patty Murray of the HELP (Health, Education, Labor & Pensions) Senate Committee:
Dear Chairman Alexander and Ranking Member Murray:
Thank you and members of the Senate Health Education Labor and Pensions Committee for your commitment to hold September hearings on actions that Congress should take to stabilize and strengthen the individual health insurance market. The State Health Exchange Leadership Network, an association of state leaders dedicated to the implementation and operation of the state-based health insurance marketplaces, appreciates this opportunity to submit testimony.
Health and Human Services Secretary Tom Price, MD, declared a public health emergency in Texas on Saturday as Hurricane Harvey was pounding the state's coast.
Harvey made landfall late Friday night with winds topping 130 mph. Forecasts called for the storm to hover over the state for 5 days or more, possibly drenching some areas with as much as 50 inches of rain. Hundreds of thousands were without power and the National Weather Service said parts of Texas could be "uninhabitable for weeks or months."
"Many Medicare beneficiaries have been evacuated to neighboring communities where receiving hospitals and nursing homes may have no health care records, information on current health status or even verification of the person's status as a Medicare beneficiary. Due to the emergency declaration and other actions taken by HHS, CMS is able to waive certain documentation requirements to help ensure facilities can deliver care," an HHS statement read.
In light of this, I thought it might be a good idea to remember his last such plan, introduced back on January 18, 2016 in the midst of his heated primary battle with Hillary Clinton.
If you visit BernieSanders.com and click on the "Issues" tab today, you can still find his official 2016 campaign "Medicare for All" plan, without a single word changed.
It's important to note that while Bernie's plan as presented on his website was not actual legislative text, it was, in his own words, the "FULL plan"...that is, this wasn't supposed to be a "summarized" version or an "overview", but literally "the FULL PLAN", as the link leading to it clearly states twice:
Amidst all the discussion and debate about how to fix/improve/strengthen/expand the Affordable Care Act, one thing I've written about as much as anyone else (and far more than many others) is people enrolled in the unsubsidized individual market. To recap: Around 18 million people are enrolled in individual market policies, of which around half (9 million) receive tax credits to help cover a chunk of the premiums. Of those, around 7 million also receive CSR assistance to help cover deductibles and co-pays. The amount/portion of their expenses which are covered varies from high to low based on a sliding income scale, and it's frankly too skimpy at the upper end of that range, but at least these folks receive some assistance.
File this one under "Be Careful What You Wish For".
Just a couple of days ago I reported that the New York Dept. of Financial Services had issued their approved 2018 rate changes for the 15 insurance carriers participating in the state's individual and small group markets...and, in some welcome news, they whittled down the rate increases by a bit, from 17.7% on average to 14.5% on average in the individual market, and from 11.7% to 9.3% in the small group market.
New York State’s biggest hospital system plans to stop selling Obamacare plans, blaming a costly plank of the law and uncertain prospects for a fix amid a wider Washington brawl over health care.
Hey Michigan Residents! Do you live in the Clinton Township area?
If so, come on out on Sunday, August 27th, and join Congressman Sander Levin, State Representative Henry Yanez and myself as we explain what the latest craziness is regarding the ACA, the GOP attempts to repeal and/or sabotage it and healthcare policy in general from 2:00pm - 4:00pm at the Clinton Macomb Public Library:
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):
Quick recap: As of 2013, the pre-ACA individual market consisted of around 10.7 million people. The vast majority of the policies these folks were enrolled in were not ACA-compliant for one reason or another, including not covering one or more of the 10 Essential Health Benefits (EHBs) required by the ACA, having annual/lifetime caps on benefits or any number of other reasons.
Under ACA regulations, non-compliant policies which people were enrolled in prior to March 2010 (when President Obama signed the ACA into law) were grandfathered in...that is, insurance carriers could continue to offer them to existing enrollees for as long as they wanted to, and existing enrollees could stay on them for as long as they wished, but they couldn't be offered to anyone else, and once a current enrollee dropped out of a grandfathered plan they aren't allowed to rejoin it later on. The number of "grandfathered" enrollees has gradually declined since 2013, of course, as people either move to other coverage, die off (hey, it happens) or the carriers decide to discontinue the policies altogether.
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.
OK, perhaps this is just me being paranoid, but then again, given the #TrumpRussia/Hacking brouhaha, perhaps not.
Like most website owners, now and then I like to check my website analytics to see how the site is doing traffic-wise. Every now and then I'll poke through the various demographics of site visitors. Once in a blue moon I'll even check which country people are visiting from. Given the nature of this site, obviously the vast majority of the traffic comes from the United States; after that, most visitors typically come from Canada, the United Kingdom or France, none of which is particularly surprising.
However, I noticed something interesting today, and decided to go back to prior years to check on something...and sure enough, guess what?
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
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.
Tuesday morning I left on a quickie family vacation to Mackinac Island; we got back into town last night, so I was gone for just 4 days. In that time, here's some of the bigger developments on the ACA/healthcare policy front:
The Congressional Budget Office issued their formal projection of the 10-year (9-year, really) impact of terminating CSR reimbursement payments permanently starting in January 2018. Their major takeaways are pretty much the same as what I and most other healthcare wonks have been projecting, with a few twists:
The fraction of people living in areas with no insurers offering nongroup plans would be greater during the next two years and about the same starting in 2020
Gross premiums for silver plans offered through the marketplaces would be 20 percent higher in 2018 and 25 percent higher by 2020—boosting the amount of premium tax credits according to the statutory formula
Most people would pay net premiums (after accounting for premium tax credits) for nongroup insurance throughout the next decade that were similar to or less than what they would pay otherwise—although the share of people facing slight increases would be higher during the next two years
Federal deficits would increase by $6 billion in 2018, $21 billion in 2020, and $26 billion in 2026
The number of people uninsured would be slightly higher in 2018 but slightly lower starting in 2020.
In general, their projections on the impact on premiums (unsubsidized and subsidized) is similar to what I, the Kaiser Family Foundation, Oliver Wyman and others have been saying all along: Around 20 percentage point increases across all Silver plans (which would be the equivalent of around 14-15% if spread out across all plans on & off the exchanges.
Hey Michigan Residents! Do you live in Michigan's 1st Congressional District? Are you sick of Jack Bergman (MI-01) refusing to even talk to you about their "replacement" healthcare bill, which would tear away healthcare coverage for millions of Americans and hurt the coverage of countless millions more?
If so, come on out to Traverse City TOMORROW, Sunday, August 20th, and join State Representatives Christine Greig (appearing in person) and myself (appearing via Skype) as we explain what the latest craziness is regarding the ACA, the GOP attempts to repeal and/or sabotage it and healthcare policy in general from 10:30am - 11:30am at the Workshop Brewery, 221 Garland St. in Traverse City:
Tomorrow afternoon, CBO expects to release a report, which is being prepared with the staff of the Joint Committee on Taxation, about the effects of terminating payments for cost-sharing reductions. The analysis will include effects on the federal budget, health insurance coverage, market stability, and premiums.
Unfortunately, I'm not going to be in a position to write anything up about the CBO report, as I'm going on a long-overdue mini-vacation to visit Mackinac Island for a few days. I'm sure I'll be chiming in via Twitter when possible, but my wife will kill me if I try to write a full blog post, so that'll be about it.
Therefore, here's my thoughts about what the CBO is likely to conclude:
The effect on the budget will depend heavily on how many carriers decide to (or are allowed to) go the "Silver Switcharoo" route with their revised/final rate filings:
As I explained a couple of weeks ago, even if CSR payments aren't made next year, there are five different paths a given insurance carrier can take for 2018:
1. Drop out of the on-exchange market so you're not at risk of having any CSR enrollees; stick around the off-exchange market.
2. Drop out of the entire individual market, both on and off exchange.
3. Preemptively cover your anticipated 2018 CSR losses by spreading them out across all plans on and off exchange.
4. Preemptively cover your anticipated 2018 CSR losses by loading them onto Silver plans only both on and off exchange.
5. Preemptively cover your anticipated 2018 CSR losses by loading them onto on-exchange Silver plans only.
Some carriers, tragically, have already thrown their hands up in the air and decided to wash their hands of the whole thing by choosing either #1 or 2 above. This includes Humana, Aetna, Wellmark and, most recently, Anthem, which is drastically scaling back their 2018 individual market participation levels.
The first one to fall was CoOportunity, which operated in Iowa and Nebraska. Their enrollments were halted in the middle of the 2nd Open Enrollment period, and they were liquidated before OE2 even finished.
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.
Date: August 10, 2017
Title: Information on Risk Adjustment Methodology and Rate Filing Deadlines
Question: What changes will be made to the risk adjustment methodology to account for recent rating practices that assume issuers of silver-level QHPs facing increased liability for enrollees in cost-sharing reduction plan variations?
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.
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,
I had already posted a partial look at the New Jersey rate hike situation a couple of weeks ago with a video in which Topher Spiro of the Center for American Progress interviewed NJ Congressman Frank Pallone about the situation. Since his comments weren't official and only referred to Horizon Blue Cross, I didn't make it an official part of the Rate Hike spreadsheet, but now I've managed to plug in the remaining carriers and here's how it looks. As expected, with Horizon holding a commanding 70% market share, the statewide average is around 8.5% if CSR payments are made and the mandate is enforced versus 21.6% if CSR payments aren't made and the mandate isn't enforced.
Also, check out Horizon's cover letter explaining the rate hike...they're not screwing around with who to pin the blame on.
North Dakota's numbers are pretty straightforward. Only three carriers, none of whch say anything about CSR or mandate concerns, so I have to assume that their requested rate increases are the best-case scenario. In addition, the KFF estimates suggest only a 5 point additional CSR factor anyway. This results in roughly a 23% average hike if CSRs are paid vs. a 28% increase if they aren't.
Last year, Blue Cross Blue Shield of Oklahoma, as the only carrier participating on the ACA exchange in the state, jacked up their premiums by a jaw-dropping 76%. This resulted in the highest statewide average rate hike in the country of 71% overall.
Well, that certainly seems to have done the trick: This year BCBSOK (still the only on-exchange player and holding over 99% of the market anyway) is requesting a (relatively) modest 8.3% average rate increase...and their filing specifically calls out both the CSR and mandate enforcement factors as being major reasons. Assuming the Kaiser Family Foundation's estimates are accurate, that means that if the CSR payments were guaranteed for 2018, BCBSOK should actually be lowering their rates slightly, to the tune of around 2.4%.
Adding in the steep hikes from off-exchange only CommunityCare (which only has 1,400 enrollees) brings the averages in at a 1.9% rate drop if CSRs are paid, and an 8.7% increase if they aren't.
The good news is that Wisconsin has one of the most robust and competitive exchange markets in the country. The bad news is that, contrary to popular opinion, "competition" doesn't by itself magically lower prices, at least not by enough. Both Anthem and Molina are leaving the ACA exchange (although Anthem is technically sticking around off-exchange), but there's over a dozen other carriers still duking it out.
According to the 11 carriers I have enrollment numbers for, the statewide average rate increase being requested is around 20.8% assuming CSR payments are made; using the Kaiser Family Foundation estimates, that translates into roughly 32.4% assuming they aren't made. Unfortunately, I can't seem to dig up the enrollment data for four carriers: Aspirus, Compcare, Wisconsin Physician Service and WPS (I think the last two are actually subsidiaries fo the same company). Wisconsin's total individual market should be roughly 280,000 people, and when you add up all the numbers I have (including Anthem/Molina) it only comes to around 180,000, so there appear to be roughly 100,000 enrollees missing among those 4 carriers, or over 35%.
I admit to being a bit confused about the distinction between BCBSSC and BlueChoice HealthPlan, which is also a BCBS carrier...I'm guessing one is for HMOs, the other for PPOs or something. In any event, BlueChoice plans appear to only be available off-exchange, and are thus not subject to the CSR issue. BCBSSC is, however, and the Kaiser Family Foundation estimates that their Silver plans would have to go up 23% if CSR payments are cut off. 87%% of SC exchange enrollees are on Silver plans, so that should be roughly 20.2% across all policies.
If CSR payments are made, South Carolina is looking at around a 13.2% average rate hikes; if they aren't, it's an uglier 32.5%.
We're heading into the home stretch now, with the only remaining "supersize" state, FLORIDA. FL has the largest exchange-based individual market enrollment, and the 2nd largest total individual market enrollment of any state in the country, surpassing California for a variety of local economic/demographic reasons. The Kaiser Family Foundation estimates that FL carriers would have to add about 25% to their Silver plan premiums in order to make up for CSR reimbursements if Trump pulls the plug and/or Congress doesn't formally appropriate them. Since 80% of FL exchange enrollees are on Silver plans, that translates to roughly a 20% additional "Trump Tax" for the CSR factor alone. Note that while none of the carriers mention the CSR issue (meaning they all assume the payments will be made), Molina does call out the individual mandate enforcement issues as being part of their 37.5% rate increase request. Unfortunately, they don't put a hard number on this.
New Hampshire's a bit of a head-scratcher this year: Of the three carriers on the individual exchange next year (each of whcih has a significant chunk of the market), Centene is requesting virtually no rate increases whatsoever...while the other two are asking to raise their rates by over 40% apiece.
Even more odd: Harvard Pilgrim's 42.5% seems to assume the worst regarding CSRs/mandate enforcement...yet Matthew Thornton (BCBS) is asking for 45.3% while assuming CSRs will be paid.
Finally, Kaiser assumes around a 10% Silver rate increase in NH if CSRs aren't paid, which translates into about 5.6% spread across the entire membership. Result: 29.1% if CSRs are paid, 34.7% if they aren't.
With Blue Cross Blue Shield of Nebraska declining to participate in the Nebraska exchange, that leaves just Medica as the sole individual market carrier. They're asking for a 16.9% average rate hike,
Interestingly, while Medica's rate filing letter clearly states that the 16.9% request assumes CSR payments will be made and the mandate will be enforced, they also list "unprecedented uncertainty/risk inherent in the marketplace" as one of the key drivers of the increase.
There's only two carriers participating in Mississippi's individual market next year (plus Freedom Life, which once again is just a shell company here). They're asking for 16.1% average rate hikes, and since there's no mention in any of the filings about CSR payments not being made or the mandate not being enforced, I'm assuming that increase doesn't account for those factors.
Massachusetts has one of the stablest statewide insurance markets, no doubt in large part due to their having instituted the precursor to the ACA, "RomneyCare", 4 years earlier. Massachusetts also merged their small business and individual market risk pools, which helps stabilize things. As a result, they have a high number of carriers participating in their ACA exchange and are among the few states with single-digit average rate hikes...assuming CSR payments are forthcoming and the individual mandate is properly enforced.
Assuming CSR payments aren't made, I used the Kaiser Family Foundation's 19% average estimate for Silver plan hikes due to the CSR factor. Since a whopping 92% of MA's exchange enrollees chose Silver plans (it looks like MA's unique "ConnectorCare" plans are considered Silver as well), that means an average CSR factor of around 17.5 points across the entire individual market.
Louisiana has 3 individual market carriers for 2018 (technically there's 4, but "Freedom Life" is basically just a shell company with a placeholder filing). Officially, they're requesting average rate increases averaging around 21.4%...but all three carriers state point-blank in their filing letters that a huge chunk of their request is due specifically to the CSR reimbursement and mandate enforcement issues. The Kaiser Family Foundation estimates the CSR issue alone adds around 20 points to Silver plans, and 71% of Louisiana exchange enrollees chose Silver, so that translatest into roughly 14.2 points across the whole market. This results in just a 7.2% average rate hike if CSR payments are made vs. 21.4% if they aren't:
I SCREWED UP ROYALLY. Instead of making a few simple corrections, I've chosen to completely rewrite this entry. My apologies for the error; full explanation and corrected data analysis below.
Longtime readers know that in addition to the core function of this site (it's right there in the title above), I'm also obsessed with tracking and breaking down the off-exchange individual market. This is easier said than done, because every state except for DC (which isn't actually a state) allows people to continue to purchase individual market policies directly through the insurance carriers...and unlike exchange-based enrollment, off-exchange enrollments don't usually have to be reported publicly. Some states require them to do so as part of internal state regulations, but they're usually a pain to get ahold of and other states protect the data as trade secrets, etc.
South Dakota is another fairly straightforward state: Two carriers, around 31,000 total ACA-compliant enrollees on & off exchange. Neither filing indicates whether they're assuming CSR payments will be made or not, so I'm assuming they're based on them being paid.
Another major state: Illinois. I've decided to scrap the "Low/High Increase" columns since they just confused people and made the table too wide, but replaced them with a new column showing the CSR factor estimate according to the Kaiser Family Foundation. Note that the percent listed will be smaller than Kaiser's estimate for each state, because their numbers only apply to silver plans, not all metal levels.
For instance in Illinois, Kaiser estimates that carriers would have to raise rates by 14% on Silver plans to cover their CSR losses. However, only 64% of Illinois exchange enrollees have silver plans to begin with, so I'm only plugging in about 9%. There are 5 carriers operating on the Illinois individual market (well, really 4, since "Freedom Life" doesn't count). I have the hard enrollment numbers for 4 of the 5; for Health Alliance Medical Plans I used 30,000 based on their 2016 number. Overall, Illinois is looking at around 11.3% w/partial sabotage, 20.3% with full sabotage:
Hawaii only has two carriers on the individual market (and in fact doesn't even have much of an individual market due to a state law mandating that nearly every business provide coverage anyway). HMSA's filing letter is very specific about calling out both the CSR and mandate enforcement sabotage factors as being part of their request. Kaiser doesn't really mention either issue at all, and the only CSR reference in the filing seemed to assume it would be paid, so I have one in each category. Kaiser Family Foundation assumes a 21% Silver CSR rate hike, and 71% of Hawaii's exchange enrollees are on Silver plans, so that amounts to roughly a 15% overall CSR factor.
Here's what it looks like...15.2% w/partial sabotage, 30.2% with full sabotage:
Whew! OK, Texas was a bear for obvious reasons...13 different carriers (well, 12 really...Centene is new to their market). Several more are dropping out (Aetna, Allegian, Cigna, Humana, Memorial Hermann and Prominence), but suposedly theyonly have around 64,000 enrollees in TX combined. Texas's total individual market is actually closer to 1.6 million, so I'm obvoiusly missing a big chunk of enrollees below (and before my regular commenters say it: Yes, I'm sure the off-exchange TX indy market has shrunk this year, but I find it hard to believe it's shrunk by over 60% already).
Anyway, I've managed to plug in one hard request percent for each carrier--the FULL Trump Tax for 3 of them, the NO/PARTIAL Trump Tax for most. In Vista's case, they're off-exchange only so the CSR issue isn't a factor anyway. Unfortunately, I can't seem to find the enrollment number for Community Health Choice, so I don't know what their share of the market is, which could make a big difference if they have high enrollment. I've plugged in a flat 100,000 enrollees for the moment, but will change that if I'm able to track the actual number down.
Another fairly straightfoward state: Three carriers, two of which (CareFirst and Health Plan of Upper Ohio Valley) appear to be assuming CSR payments will be paid; the third, Highmark BCBS (which holds the vast bulk of the individual market) openly states that they assume they won't be made and that the mandate won't be enforced to boot. I'm once again assuming roughly 2/3 of Kaiser Family Foundation's "Silver CSR hike", which in this case would be about 10%, giving the following: 17.8% if CSR payments are made, 27.8% if they are:
Louise Norris gave me a heads up that the Kentucky Insurance Dept. has posted their 2018 rate hike filings as well. The individual market is pretty straightforward...and pretty grim: Both individual market carriers, CareSource and Anthem, are asking for pretty steep rate hikes even if CSR payments are locked in next year, averaging around 30.8%, while assuming another 13.5 points on top of that (71% of Kaiser's 19% Silver average) would bring the average up to around 44.3%. Not much else to say about this one for the moment.
The states filings are piling up quickly...Arkansas is pretty straightforward. Interestingly, four of the five carriers seem to be assuming that CSR payments will be made, and have submitted their rate filings accordingly; the fifth (and largest), USAble Mutual (aka Blue Cross Blue Shield of AR) is the only one to break it out specifically. In order to estimate the CSR factor for the other 4 carriers, I'm assuming 2/3 of Kaiser's 15% Silver plan bump estimate, or around 10 percentage points. That brings things in at around 10% even without CSR sabotage or nearly 18% with the CSR factor.
One other important thing to keep in mind regarding Arkansas: Their total individual market, including grandfathered and transitional plans, is something like 430,000 but they only have around 70,000 officially enrolled in ACA exchange policies. The main reason for this is that they have another 320,000 people enrolled in exchange policies via their "Private Medicaid Option"...which is Arkansas' version of ACA Medicaid expansion. For some reason, those folks aren't counted as ACA exchange enrollees even though it's my understanding that the only distinction between them and the 70K official enrollees is where the payments/subsidies come from.
In late May, I noted that Blue Cross Blue Shield of North Carolina, which holds a near monopoly on the individual market in NC with around 95% of total enrollment, had submitted an initial rate hike request for 2018 averageing 22.9% overall. What was remarkable at the time is that while most carriers were pussyfooting around using euphamisms about the reasons for their excessive increase requests, BCBSNC was among the first to come right out and state point-blank that it's the Trump Administration's deliberate sabotage of the market--primarily via the threats to cut off CSR payments and to not enforce the individual mandate--that are responsible for over 60% of the increase. This is from their blog, not mine:
48 hours ago I posted this analysis/explainer of the "Silver Switcharoo", the goofy, bass-ackwards workaround which insurance carriers and state regulators could (if necessary) use to resolve Donald Trump's impending threat to pull the plug on Cost Sharing Reduction subsidy reimbursement payments.
There's been a whole bunch of additional CSR-related developments since then:
Congressional Republicans moved on Tuesday to defuse President Trump’s threat to cut off critical payments to health insurance companies, maneuvering around the president toward bipartisan legislation to shore up insurance markets under the Affordable Care Act.
Alabama, Alaska and Wyoming only have a single insurance carrier participating in each of their individual markets. While this is a bad thing from a competitiveness POV, it cetainly makes things easier for me from a tracking-average-rate-hikes POV.
ALSO IMPORTANT: The HHS Dept. is also starting to upload the rate filings to the official RateReview.Healthcare.Gov database, which should make things easier for me going forward (assuming that the data is uploaded properly and isn't messed with, which is a distinct possibility when it comes to the Trump Administration)
Officially, Alabama has the infamous "Freedom Life" phantom plan which is asking for a whopping 71.6% rate hike...to allegedly cover exactly one (1) person statewide. Un-huh.
Aside from that, however, it's Blue Cross Blue Shield across all three states...and they're asking for the following:
This isn't a full analysis, since I only have 2018 rate hike data for one of Arizona's carriers so far...on the other hand, AZ only has a couple of carriers on the individual market these days anyway. From AZCentral:
The Affordable Care Act insurer in 13 of Arizona's 15 counties plans to raise average rates across all plans a moderate 7.2 percent next year.
But Blue Cross Blue Shield of Arizona officials said the rate increases would be flat if President Donald Trump's administration did not plan to eliminate a key Affordable Care Act funding source.
7.2% isn't bad at all...of course, that comes after last years massive 57% average rate hike. Still, 0% would obviously be much better than 7%...
Trump suggested in a weekend tweet that " ... bailouts for insurance companies and bailouts for members of Congress will end very soon" unless Congress acts quickly on a new health bill.
Covered California Releases 2018 Rates: Continued Stability and Competition in the Face of National Uncertainty
Covered California remains stable, with an average weighted rate change of 12.5 percent. The change is lower than last year and includes a one-time increase of 2.8 percent due to the end of the health insurance tax “holiday.”
The competitive market allows consumers to limit the rate change to 3.3 percent if they switch to the lowest-cost plan in the same metal tier.
For 2017, unsubsidized enrollees on the Minnesota individual market faced massive rate hikes averaging 57%. It was so bad that the only way they could convince some carriers to participate in the market was to allow most of them to put a cap on how many people they'd enroll (with the balance being shunted over to Blue Plus, the HMO division of BCBSMN). This resulted in a massive initial surge of enrollment, as it was on a first-come, first-serve basis...but also left off-exchange and unsubsidized exchange enrollees high and dry.
In response, the state scrambled to pull together a $300 million package to help supplement premiums for those folks...knocking a flat 25% off of their premiums for 2017. This helped ease the problem in the short term, but the larger issue still loomed going forward.
It feels almost silly for me to spend so much time crunching the average 2018 rate hike numbers at this point. Between the (supposedly failed?) GOP repeal effort and Donald Trump's ongoing sabotage efforts--including what could be him officially pulling the plug on CSR reimbursements as early as sometime today--it's probably a bit of a futile effort. Besides, a dozen other wonks/analyses have already confirmed what the Kaiser Family Foundation projected months ago and which I've been proving on a state-by-state basis for months now: The CSR threat is causing average rate hikes of around 20 points on average, and the threats to individual mandate enforcement are tacking on another 4-5 points on top of that, beyond the ~10 points which rates would normally be increasing on average.
