Arizona Announces Extension of Major Medical Transitional Policies Until Further Notice
Phoenix - The Arizona Department of Insurance and Financial Institutions (DIFI) announced that insurers in the individual and small group major medical health insurance markets can choose to renew "transitional policies" for a policy year beginning after October 1, 2022, and thereafter until CMS modifies its non-enforcement policy. Transitional policies are policies that individuals had in place before the Affordable Care Act went into full effect on January 1, 2014.
This extension aligns with the extension announced by the Center for Consumer Information and Insurance Oversight (CCIIO) in Insurance Standards Bulletin Series – INFORMATION – Extension of Limited Non-Enforcement Policy through 2023 and Later Benefit Years. The Bulletin gives insurers the option to annually renew applicable pre-2014 individual and small group policies until further notice. Approximately 30,000 Arizonans have health insurance coverage through a transitional plan.
Grandfathered Policies: These are non-ACA compliant policies which people were already enrolled in prior to March 2010, when the ACA was signed into law. Anyone enrolled in one of these can keep renewing them until the day they die if they wish (as long as they keep paying the premiums), or until the carrier chooses to (voluntarily) discontinue the policy.
Transitional (or "Grandmothered") Policies: These are non-ACA compliant policies which people enrolled in between March 2010 and October 2013. This category was created by President Obama and the HHS Dept. in November 2013 during the ugly "If You Like Your Plan You Can Keep It!" backlash. Basically, the ACA originally would have required that these policies be terminated as of 12/31/13. However, after a bunch of people received cancellation notices from their carrier, there was a massive backlash, leading Obama to announce an extension program.
OK, my math here is gonna be a bit sloppy, but I'm just trying to illustrate a larger point about how splitting risk pools is, generally speaking, a Bad Thing.
Under the Affordable Care Act, non-ACA compliant healthcare policies were given until December 31st, 2013 to become fully ACA-compliant, including the new regulations mandating guaranteed issue, community rating, essential health benefits, no more annual or lifetime limits on coverage and so forth. All major medical policies offered from that day forward had to be fully ACA compliant (although there were some exceptions for short-term plans and so forth).
However, there was an exception made: Any existing policy which someone had been continuously enrolled in since before the ACA was signed into law by President Obama in March 2010 was considered to be "grandfathered" in. As long as the insurance carrier chose to keep offering those non-compliant policies, existing enrollees could remain enrolled, although premiums would of course increase from time to time. The "locked in" pool of enrollees would gradually dwindle as enrollees died, aged onto Medicare, got jobs with employer coverage and so on.
Earlier today I noted that RateReview.HealthCare.Gov, which is a public-facing searchable database for annual health insurance policy premium rate changes, has gone through some updates on the ACA-Compliant side.
I also noted that the other section of the database, which tracks non-ACA compliant rate changes for "Transitional Plans" and "Student Plans", may have had some updates as well, but it's hard to say since I've poked around there so rarely. This morning I decided to rectify that by searching through the entire Transitional/Student plan database and compiling the results. Unlike the ACA side, there's no way of filtering it out by year, so the following table includes every rate change filing entry listed...and the results surprised me:
The total individual/family policy health insurance market was roughly 10.6 million people in 2013. This included people enrolled in either "grandfathered" policies (i.e., policies enrolled in prior to the ACA being signed into law in 2010) or in "transitional" policies (those enrolled in between 2010 and late 2013, just before the ACA required all new individual market policies to be fully compliant with the new healthcare law.
How many of those 10.6 million people are still enrolled in grandfathered (GR) or transitional (TR) policies today? Unfortunately, there seems to be very little available data about just how many people are still in these policies. The Kaiser Family Foundation gave a rough estimate of around 2.1 million people last year, which sounded about right to me. However...Kaiser didn't include a state-level breakout of their estimates, and of course it's a year later so that number, if accurate, has probably shrunk a bit more.
The total individual/family policy health insurance market was roughly 10.6 million people in 2013. This included people enrolled in either "grandfathered" policies (i.e., policies enrolled in prior to the ACA being signed into law in 2010) or in "transitional" policies (those enrolled in between 2010 and late 2013, just before the ACA required all new individual market policies to be fully compliant with the new healthcare law.
How many of those 10.6 million people are still enrolled in grandfathered (GR) or transitional (TR) policies today? Unfortunately, there seems to be very little available data about just how many people are still in these policies.
Ever since I laid into Congressional Republicans on Friday for deliberately sabotaging the funding program for the ACA's CO-OP Risk Corridor program last December, several people have correctly pointed out that, while having federal funds cut for this program cut off was certainly a major factor in at least one of the CO-OPs going under (the Kentucky Health CO-OP), there was a different policy change--made nearly 2 years ago--which may also contributed to their financial woes (and which may have played a role in some of the other 4 CO-OPs which fell apart prior to the risk corridor debacle hitting home a week or so ago).
Last week I took the known 2016 Florida rate increase requests (around 14.7% weighted average for 10 companies with around 713,000 enrollees) and took my best shot at trying to estimate what the rest of Florida's ACA-compliant individual market might look like.
In order to do this properly, I'd need 2 pieces of data: First, the weighted average increase request for the 6 additionalcompanies which I didn't already have rate requests for; and second, the total ACA-compliant enrollment number for those 6 companies.
