Consumer Alert on Potential Unlicensed Health Insurance Company
CONCORD, NH – As a result of a recent Georgia court order, the New Hampshire Insurance Department is advising consumers that Aliera, a company that markets itself as a health care sharing ministry, may be operating illegally in New Hampshire.
I realize this may seem a bit late in the game seeing how the 2019 ACA Open Enrollment Period has already started, but I do like to be as complete and thorough as possible, and there were still 9 states missing final/approved premium rate change analyses as of yesterday which I wanted to check off my 2019 Rate Hike Project list.
Fortunately, RateReview.HealthCare.Gov has finally updated their database to include the approved rate changes for every state, which made it easy to take care of most of these. In addition, in a few states the insurance department has also posted their own final/approved rate summary.
CONCORD, NH -- Open enrollment in the individual Health Insurance Marketplace will run from November 1 to December 15. In advance of open enrollment on and off the federally facilitated Marketplace, the New Hampshire Insurance Department offers information and resources for the approximately 54,000 state residents who will purchase health insurance in the individual market for 2019 coverage.
"We are encouraging New Hampshire residents who are buying a plan on Healthcare.gov to update their applications and actively compare plan options, “ said New Hampshire Insurance Commissioner John Elias. “Buying insurance is signing a contract. Once you lock in coverage, your rates and cost-sharing amounts will stay the same all year. But if you don’t sign up now, you will not have another chance to enroll until next year – unless you have a qualifying life event.”
With just 3 weeks to go before the 2019 Open Enrollment Period begins, the dust has mostly settled on my 2019 Rate Hike Project. Over half the states have provided their final, approved individual market premium changes, and while I haven't found the final rates for the other half yet, their preliminary rates are all on record, so I don't anticipate the needle moving too much at this point.
New Hampshire is among the states which I haven't found final rate changes for yet. The three carriers in the state have requested average price reductions of around 13.5% on average, which is well below the 3.2% increase which is the average nationally, but I still don't know what the state regulators are going to approve.
This makes the following press release rather surprising:
NH Insurance Department to Hold Oct. 30 Annual Public Hearing on Health Insurance Premiums
New Hampshire is perhaps the most striking example of both insurance carriers significantly overshooting the mark for 2018 premiums while also proving my point that just because premiums are dropping next year, #ACASabotage is still causing unsubsidized enrollees to pay a lot more than they'd have to otherwise.
All three of the carriers offering ACA policies on New Hampshire's individual market are reducing their 2019 premiums, by anywhere from 7.4% for Harvard Pilgrim to a whopping 15.2% in the case of Ambetter/Celtic.
THe enrollee market share numbers come from the monthly report from the New Hampshire insurance department (I'd love it if every state required one of these...it includes both on and off-exchange enrollees). The "PAP" column refers to NH residents enrolled in their "private option" Medicaid expansion program...but those are still part of the same risk pool as the other enrollees, so they still have to be factored into the market share formula.
As noted earlier today, I've now managed to plug 48 states (plus DC) into my 2018 Rate Hike Project spreadsheet. This leaves just two states missing: New Hampshire and Texas. I'm still waiting to clarify some things for each, so this analysis could still change, but I really want to wrap this up, so here's what I have for New Hampshire right now:
When I first ran the numbers for New Hampshire'srequested 2018 rate increases, it seemed pretty straightforward: 3 carriers on the individual market. 2 listed rate changes assuming CSRs would be paid; one assumed they wouldn't. This gave the following:
Did CMS execute a last-minute reversal on navigator program? That's what independent blogger Charles Gaba is reporting, posting what appear to be internal CMS documents that show the agency was poised to essentially renew last year's funding for this year's ACA open enrollment.
One document posted by Gaba indicates that Randy Pate — tapped by the Trump administration to run Medicare's Center for Consumer Information and Insurance Oversight — signed off on $60 million in program funding on Aug. 24. More. However, CMS ultimately funded the program at less than $37 million for the upcoming enrollment, a 41 percent cut from last year.
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.
Of course, as I (and others on both sides of the political spectrum) have written about many, many times, not everyone who selects a QHP (either on or off the exchanges) actually pays their first premium, and therefore is never actually enrolled in an active, effectuated policy. This amounted to roughly 12-13% of all QHP selections in 2014, but has improved over the past 3 years as people got used to how the system works and technical improvements were made. I've been using a 10% non-payment rate as a general rule of thumb for some time now.
In New Hampshire, assuming 58,000 people enroll in private exchange policies by the end of January, I estimate around 31,000 of them would be forced off of their private policy upon an immediate-effect full ACA repeal, plus another 50,000 enrolled in the ACA Medicaid expansion program, for a total of 81,000 residents kicked to the curb.
As for the individual market, my standard methodology applies:
(sigh) OK, with three states still missing, you just knew I wouldn't rest until I was able to fill in the missing pieces of the puzzle. Sometime today, the HHS Dept. finally entered the approved rate hikes for individual makret carriers in two of those states: New Hampshire and Virginia. Louisiana is still AWOL for whatever reason.
It's important to note that sometimes the "Final Rate Increase" percentages listed at RateReview.HealthCare.Gov dont' actually end up matching the approved rate hikes found in the official SERFF databases or even at the state's Dept. of Insurance website. Normally I cross-check all three to make sure nothing weird is going on, but given that it's well past time to move on, I'm relying purely on the RateReview numbers for these states.
With that in mind, here's what it looks like in each:
When I originally calculated the average requested rate hike for New Hampshire, I came up with a weighted estimate of around 13.1%. A month later, the average dropped a few points...but not for a good reason: One of the remaining ACA-created Co-Ops, Community Health Options, decided to pull out of New Hampshire (they started out as a Maine-only operation, expaneded into nearby NH for the 2nd and 3rd year, but are pulling back to Maine-only again). Since CHO would otherwise have been requesting a more than 40% increase, them dropping out actually lowered the average increase for everyone else. This obviously illustrates a major caveat with my "average rate increase" methodology: It only applies to those who are able to renew their existing plans. The moment a carrier pulls out of parts/all of a state, or drops PPOs (while keeping HMOs), etc, I have to remove a portion of the existing enrollees from the equation completely.
Community Health Options, a Lewiston-based health insurance cooperative, has gotten approval to withdraw from the New Hampshire insurance market in 2017.
The plan was approved this week by the Maine Bureau of Insurance, which has been monitoring CHO’s finances as it tries to recover from a $31 million loss in 2015. The nonprofit cooperative has set aside more than $45 million in reserves to try to avoid another big loss this year.