OE5

2018 MIDTERM ELECTION

Time: D H M S

There were several stories over the past few days about a new, just-released report from the General Accounting Office (GAO) which examined how well/poorly the Trump Administration handled the 2018 Open Enrollment Period last year.

Many of the findings were things which I had been either predicting or documenting all year:

  • Enrollment through Healthcare.gov Was 5 Percent Lower in 2018 than 2017
  • Stakeholders Reported That Plan Affordability Likely Played a Major Role in Enrollment
  • HHS Reduced Consumer Outreach for 2018 and Used Problematic Data to Allocate Navigator Funding
  • HHS Did Not Set Numeric Enrollment Targets for 2018, and Instead Focused on Enhancing Certain Aspects of Consumers’ Experiences

We identified a list of factors that may have affected 2018 healthcare.gov enrollment based on a review of Department of Health and Human Services information, interviews with health policy experts, and review of recent publications by these experts related to 2018 exchange enrollment.

Factors related to the open enrollment period:

If you've followed this site for awhile, you may recall that about a year ago, I called out the Centers for Medicare & Medicaid (CMS) for trying to pull a fast one regarding the 2017 Open Enrollment Period data.

The short version is that they tried to make it look as though only 10.3 million of the 12.2 million people who selected Qualified Health Plans (QHPs) from the ACA exchanges actually paid their first month's premium and were actually enrolled (i.e., "effectuated"), or around 84%. They then tried using this "fact" as evidence of how the ACA was failing, etc etc, because this was supposedly down from 2016 levels.

The difference, as I noted at the time, is that the 2016 effectuation numbers were as of March, while the 2017 effectuation numbers were as of February. This made a big difference, because around 500,000 people who enrolled during 2017 Open Enrollment couldn't have been effectuated for February...because about half a million people enrolled between Jan. 16th - Jan. 31st, which meant their policies weren't even scheduled to begin until March.

A few days ago, the Centers for Medicare & Medicaid released three important new reports on the 2018 Open Enrollment Period and trends in the individual market. There's a lot of data to go over, so I'm breaking my analysis into several smaller posts for easier readability.

OverviewPart OnePart TwoPart ThreePart Four

OK, next up: HOW MANY HAVE PAID???

This Just In...

Centers for Medicare and Medicaid Services Releases Reports on the Performance of the Exchanges and Individual Health Insurance Market
Reports show individual market erosion and increasing taxpayer liability

Um...yeah, deliberately sabotaging the ACA a dozen different ways and cutting off CSR reimbursement payments, thus forcing the carriers to load CSR costs directly onto premiums, which in turn jacks up APTC subsidies accordingly, will have the effect of "increasing taxpayer liability"). Go on...

A few days ago, I ran a comparison of the average unsubsidized (full price) 2018 premium increases for each state which I had projected last fall against a study last month by the Urban Institute in which they reported the actual average premium increases, by state, of some of the ACA policies available on the exchange. Urban wasn't able to examine every plan, but they did a full analysis on the Lowest Cost Silver, 2nd Lowest Cost Silver (benchmark plan) and Lowest Cost Gold policies in each market and statewide.

Urban's analysis concluded that depending on how you looked at their data, the overall national average increase was between 29-32% year over year...versus my own national projection of around 29.7%.

I didn't fare so well at the state level: I was within 5 percentage points of their actual averages in 31 states, and within 10 points in 6 more. I was way off in the other 14 for various reasons.

OK, I'm finally able to get back to digging into the meat of the FINALLY just-released 2018 Open Enrollment Report from the Centers for Medicare & Medicaid.

In Part 2, I'm looking at the actual 2018 Open Enrollment Period Public Use Files, which break out a ton of demographic info by state, county and even zip code depending on the state (some of it is available for all 50 states + DC, while other data is only available for the 39 states hosted by HealthCare.Gov).

First up: As I noted earlier today, there's around a 10,000 enrollee discrepancy between the national total I came up with back in early February and CMS's official total. I compared my state-by-state totals against CMS's report and found differences in 5 of the state-based exchanges:

NOTE: THIS IS A LIVE BLOG, SO CHECK BACK FREQUENTLY FOR UPDATES.

Yes, at long last (3 weeks later than last year, which itself was 4 days later than in 2016), the Centers for Medicare and Medicaid has finally released the official, final 2018 Open Enrollment Report. Let's dig in!

This report summarizes enrollment activity in the individual Exchanges during the Open Enrollment Period for the 2018 plan year (2018 OEP) for all 50 states and the District of Columbia. Approximately 11.8 million consumers selected or were automatically re-enrolled in Exchange plans during the 2018 OEP. An accompanying public use file (PUF) includes detailed state-level data on plan selections and demographic characteristics of consumers. The methodology for this report and detailed metric definitions are included with the public use file.

Regular readers know that I've developed a tradition over the past three years of tracking the average unsubsidized premium rate increases for the ACA-compliant individual market, painstakingly poring over the rate filings for every carrier in every state and running a weighted average by their market share.

Every year there are numerous challenges and headaches which get in the way, including things as obvious as "not every carrier publishes the number of enrollees they have covered" to complex situations like "carrier X is dropping out of the on-exchange market in half the counties of the state but is sticking around in the off-exchange market". In addition, many carriers submit an initial rate request...followed a few months later by a revised one...neither of which might end up matching the final premium changes approved by state regulators. Sometimes there may be 2-3 more revised filings along the way which muddy the waters even further.

Over a month ago I posted what I assumed was the final 2018 Open Enrollment Report from the Washington HealthPlan Finder. However, it appears that was just a partial report. Today they announced the official version:

The Washington Health Benefit Exchange today announced that 209,802 customers used Washington Healthplanfinder to purchase a Qualified Health Plan (QHP) for 2018 coverage during the most recent open enrollment period. This total is a nearly three percent increase over last year and is 50 percent higher than the number of enrollees recorded following the first open enrollment period in 2014.

Huh. This is kind of odd.

Minnesota's 2018 Open Enrollment Period was a month longer than the official half-length period pushed by HealthCare.Gov, but was still over 2 weeks shorter than it had been in prior years, ending on January 14th, 2018. Even so, they reported a slight increase in year-over-year policy enrollees, ending OE5 with 116,358 QHP selections.

Typically, you'd see the official QHP selection number drop off noticeably by the end of the first quarter...usually by around 13% or so. Roughly 10% of those who select policies don't ever actually pay for their first monthly premium, and another 2-3% generally drop off after only paying for the first couple of months.

I'm not sure how I of all people managed to miss this, but Connect for Health Colorado released their official 2018 Open Enrollment Period report over a week ago:

We released our End of Open Enrollment report this week, our most detailed look at the impact we are having across Colorado. This year, you will see that more of our customers are receiving help through the Advance Premium Tax Credit – 69 percent, compared to 61 percent last year – and the average level of monthly tax credit help climbed to $505 from $369 last year.

Not surprising...the 34% average rate increases (about 6 points of which is due specifically to CSR reimbursement payments being cut off...much lower than most states) meant that a lot more people qualified for tax credits in the first place, and of course the amount of credits went up accordingly...a bit more, actually (37% on average).

Press Release: NY State of Health Releases 2018 Enrollment by Insurer
Mar 14, 2018

Consumer Choice Continues to be a Hallmark of the Marketplace

ALBANY, N.Y. (March 14, 2018) -- NY State of Health, the state’s official health plan Marketplace, today released data showing 2018 health plan enrollment by insurer. Statewide, 12 health insurers offer Qualified Health Plans (QHP) to individuals and 15 health insurers offer coverage to Essential Plan (EP) enrollees through the Marketplace. Ten health insurers participate in all individual market programs offered through NY State of Health allowing consumers a smooth transition if their program eligibility changes. Throughout the 2018 Open Enrollment Period, most consumers had a choice of at least four health insurer options in every county of the State. 

I just did a light analysis of how many people would be helped or hurt by CSR funding in 2019 in Rhode Island, and concluded that at least 28% of exchange enrollees would see their premiums increase if CSR funding was restored, while only perhaps 2-3% would see their premiums drop.

It turns out that over the weekend, my colleague Xpostfactoid did a much deeper analysis of the same situation in Maryland:

So there you have the enrollment results of full-bore on-exchange silver-loading of CSR costs in one state. In all, 49,993 on-exchange enrollees with incomes up to 400% FPL chose plans other than silver. About 48,000 of them were subsidized. That's 31.2% of all enrollees, within striking distance of Aron-Dine's upper bound of 36% for all marketplace enrollees.

HealthSource RI, Rhode Island's ACA exchange, released preliminary 2018 Open Enrollment data awhile ago, but this morning they released their final, official demographic data breakout, and there's a lot going on here:

HealthSource RI sees 5% enrollment increase and nation leading lowest benchmark plan cost
State-based marketplace sees rise in enrollment of “young invincibles”

Over the past few weeks,I've posted partial 2018 Open Enrollment Period demographic data from Connecticut, Idaho, Maryland, New York and Washington State. Still missing are final wrap-up reports from the other 7 state-based exchanges...as well as The Big One: The official report from the Assistant Secretary for Planning and Evaluation (ASPE).

The 2014 ASPE report was released on May 1st, 2014...just 17 days after the first, tumultuous 2014 Open Enrollment Period ended (only 12 days, really, since the report actually ran through April 19th, 2014 even though the "overtime" period technically ended on April 15th).

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