Mandate Repeal

Hat tip to Louise Norris for the heads up about the Kentucky Dept. of Insurance issuing their final rulings for 2019 ACA individual market and small group policy premiums:

DOI Completes Review of Individual and Small-Group Health Insurance Rate Filings

The Kentucky Department of Insurance (DOI) announced today that it has completed its review of the individual and small-group insurance rates filed in the Kentucky market. The rates will be used to calculate insurance premiums in the 2019 benefit year.

Kentuckians in the individual market will once again experience changes in premiums and plan offerings. The rates that will be used reflect an average rate increase of 4.3 percent for Anthem Health Plans of Kentucky (Anthem) and 19.4 percent for CareSource. Since the actual premium charged will vary by individual and the plan level selected, some individuals may see a decrease in rates.

This just in from the Florida Office of Insurance Regulation...

OIR Announces 2019 PPACA Individual Market Health Insurance Plan Rates  

TALLAHASSEE, Fla. – The Florida Office of Insurance Regulation (OIR) announced today that premiums for Florida individual major medical plans in compliance with the federal Patient Protection & Affordable Care Act (PPACA) will increase an average of 5.2 percent beginning January 1, 2019. Per federal guidelines, a total of nine health insurance companies submitted rate filings for OIR’s review in June with final rate determinations due by August 22, 2018. 

Following OIR’s rate filing review, the average approved rate changes on the Exchange range from a low of -1.5 percent to a high of 9.8 percent. This information can be located in the Individual PPACA Market Monthly Premiums for Plan Year 2019 document available here.

When I first ran the preliminary 2019 ACA individual market rate filings for Virginia way back in May, I concluded that the average premium increase will be around 13.4%. However, a lot has changed since then.

For one thing, Virginia expanded Medicaid to 400,000 low-income residents, which should help improve the ACA risk pool and in turn knocked the average rate increase down by 2.2 points, to around 11.3%.

For another, Anthem made a last-minute decision to expand their coverage areas in the state dramatically, which also provides much-needed competition for Optima in the Charlottesville area, among others.

With the deadline for submitting 2019 rate filings having passed a week or so ago, the approved rates from the various state insurance regulators have been popping up left and right. Today I took a look at the Arkansas Insurance Dept. website and sure enough, they've posted the approved filings for all 4 carriers on the individual market (as well as the small group market).

On the one hand, the statewide average rate increase hasn't changed much from the preliminary average; it dropped 0.4 points from 4.5% to 4.1%...and some of that change is simply because I had misestimated the actual enrollment/market share for a couple of the carriers.

On the other hand, in Arkansas, at least, it appears that the carriers don't think the repeal of the individual mandate and/or the Trump Administration's expansion of short-term and association health plans will have nearly as big of an adverse selection impact as other estimates/projections have...including my own.

Busy day today! State insurance regulators around the country appear to have decided to start posting approved 2019 ACA rate filings all at once; within the past week, Vermont, Ohio, Delaware and North Carolina have posted theirs...and now you can add Georgia to the list:

The Obamacare rates for next year are in, and it’s a first: Rates are going down.

Following years of steep price hikes, two of the four companies that offer plans on the Affordable Care Act exchange in Georgia, also known as Obamacare, have proposed to lower their rates next year from what they charged in 2018.

According to figures for the individual insurance market released Thursday by the state Department of Insurance, Blue Cross Blue Shield of Georgia is proposing a tiny decrease in premiums for next year, with 2019 premium prices that are on average 0.3 percent lower than 2018’s premiums. Alliant Health Plans is decreasing its premiums by 10 percent.

North Carolina has three insurance carriers offering individual market policies next year: Blue Cross Blue Shield, which holds a whopping 96% of the individual market; Cigna, which holds the remaining 4%, and newcomer Ambetter (aka Centene).

I ran a write-up on BCBSNC's preliminary 2019 rate request at the end of July. While they're lowering their 2019 premiums by 4.1%, they also made it very clear that yes, they'd be lowering rates even further if not for the ACA's individual mandate penalty being repealed:

BLUE CROSS NC FILES TO LOWER ACA RATES BY AVERAGE OF 4.1 PERCENT

Durham, N.C. – Blue Cross and Blue Shield of North Carolina (Blue Cross NC) announced today it requested an overall average rate decrease of 4.1 percent for 2019 Affordable Care Act (ACA) plans offered to individuals. The reduction marks the first rate decrease in the history of Blue Cross NC since entering the current individual market more than 25 years ago.

...Many factors went into the Blue Cross NC’s rate filing:

As I noted back in June, the Ohio Insurance Dept. doesn't seem to like providing a whole lot of detail about their insurance rate filings on their website; at the time, they only stated the following regarding the preliminary 2019 individual market rate filings:

In 2018, 8 companies sold health insurance products on the exchange in Ohio and 42 counties had just one insurer with an additional 20 counties having only two.

For 2019, 10 companies have filed rates and forms for the Department to review and all 88 counties will have at least one insurer. Preliminary filings show 16 counties with just one insurer and 33 counties with two.

Huh. This is very odd. Delaware has only a single insurance carrier, Highmark, participating in the individual market next year. They requested an average 2019 rate increase of 13%.

Not only was 13% the amount on the filing form itself, it's also the average increase requested according to the summary at RateReview.HealthCare.Gov:

When I first analyzed Vermont's 2019 ACA policy rate filings back in May, the state's two ACA carriers, Blue Cross Blue Shield and MVP Healthcare, were requesting average premium increases of 7.5% and 10.9% respectively.

Vermont's situation is unusual compared to most other states for a couple of reasons. First of all, VT is one of only two states (Massachusetts is the other one) which has merged their Individual and Small Group market risk pools into one to help stabilize both markets. This is something I wish every state would do, frankly, although it's probably a lot easier to do in deep blue states (and Vermont having such a small population probably made it easier as well).

A few weeks ago, I posted about New Jersey's preliminary 2019 ACA-compliant individual market rate filings. At the time, the official New Jersey Dept. of Banking & Insurance specifically stated that:

• Because Congressional Republicans repealed the ACA's Individual Mandate Penalty, carriers were planning on increasing 2019 premiums by 12.6% on average, in part to account for the adverse selection which was expected to happen next year.

• However, thanks to the Democratically-controlled New Jersey state legislature and Governor swiftly reinstating the ACA individual mandate, actual 2019 rate filings are only expected to increase rates an average of 5.8%, saving the average unsubsidized indy market enrollee around $470 apiece next year.

• Finally, the NJ legislature also passed, and Governor Murphy signed into law, a robust reinsurance bill which, if approved by CMS, is expected to lower unsubsidized 2019 premiums by an additional 15 percentage points, for a final 2019 average premium reduction of around 9.2%.

• It's also important to understand that New Jersey's portion of the funding for the proposed reinsurance program will be coming from the revenue generated by the reinstated mandate penalty itself.