Last year I wrote a LOT about Silver Loading and Silver Switching for 2018...basically, the way which ACA individual market enrollees can save hundreds or even thousands of dollars on their 2018 insurance policies by taking advantage--perfectly legally and ethically--of the unusual pricing of different metal level policies this year.
The short version is this: Due to the way the ACA's tax credit formula works, Donald Trump's attempt at sabotaging the ACA exchanges by cutting off Cost Sharing Reduction (CSR) reimbursement payments to insurance carriers actually (partly) backfired on him, resulting in an unusual situation in which several million subsidized enrollees ended up benefitting from the pricing fallout, while millions of unsubsidized enrollees ended up being hurt by it...but other unsubsidized enrollees ended up being able to avoid being hurt by switching to a special off-exchange Silver plan (thus, the "Silver Switch").
OK, I had kind of forgotten about this. Back in early June, insurance carriers in Pennsylvania submitted their preliminary 2019 ACA market premium change requests. At the time, they averaged around a 4.9% increase statewide, which seemed pretty impressive under the circumstances.
Then, late July, the PA insurance department issued a press release stating that state regulators had modified the 2019 requests, and that the new, revised average was much lower...a mere 0.7% average rate hike. However, the individual carriers as well as the insurance department made it very clear that this nominal increase included a 6 point rate increase to account for the ACA's individual mandate being repealed and the Trump Administration's expansion of non-ACA compliant short-term and association plans.
However, the DC exchange board was also working quickly in an attempt to counter the Trump Administration's #ACASabotage factors, by voting to restrict short-term plans, to lock in DC's Open Enrollment Period at a full 3 months as in years past, and to reinstate the ACA's individual mandate penalty at the local level.
Premium Rates for Individual and Small Group Markets Individual plan premium rates may vary by age, rating area, family composition and tobacco usage. For example, a person living in Manhattan, KS (rating area 3) may pay a different rate than someone living in Pittsburg, KS (rating area 7) based on the claims data by rating area. A map of the counties included in each rating area is provided on the next page. Kansas is an effective rate review state, which means the actuarial review is conducted by the Kansas Insurance Department. KHIIS (Kansas Health Insurance Information System) claims data is utilized during the rate review process to verify the claims experience submitted by the companies. The following table provides details regarding the average requested rate revisions for companies writing individual policies in Kansas. Rate increases will be partially offset for individuals receiving a premium tax credit.
The Department of Insurance received preliminary 2019 health plan information from insurance carriers on June 1 and began reviewing the proposed plan documents and rates for compliance with Idaho and federal regulations. The Department of Insurance does not have the authority to set or establish insurance rates, but it does have the authority to deem rate increases submitted by insurance companies as reasonable or unreasonable. After the review and negotiation process, the carriers submit their final rate 2019 increase information. The public is invited to provide comments on the rate changes. Please send any comments to Idaho Department of Insurance.
UPDATE 10/30/18: Thanks to some additional reviews/checking by Dave Anderson, Louise Norris, Andrew Sprung and myself, I've been able to update the spreadsheet further; the blog post has also been updated correspondingly.
Wisconsin has an interesting situation. On the one hand, the state has what should be a robust, highly-competitive individual insurance market,with over a dozen carriers offering policies throughout the state. Granted, some of them are likely limited to only a handful of counties, but in theory they should be doing pretty well compared to rural states like Oklahoma or Wyoming, which only have a single carrier on the exchange.
I ran the numbers for Illinois' requested 2019 ACA individual market rate changes back in August. At the time, the weighted year-over-year average was a mere 0.7% increase, with Cigna and Health Alliance's 10% and 7.5% being mostly cancelled out by Celtic's 1.1% and especially Blue Cross Blue Shield's slight drop of 0.9%. Since BCBSIL holds something like 3/4 of the state's individual market share, that alone mostly wiped out the other increases.
Unfortunately, I don't have access to the hard enrollment numbers, so this was a rough estimate based on 2017's breakout. Here's what it looked like at the time:
The final unsubsidized rates are down about one point more, down 6.3% from 2018 rates. However, as all three current carriers clearly noted in August, the repeal of the ACA's individual mandate and expansion of short-term and association health plans (aka #ShortAssPlans) still caused a significant premium increase, which means without those factors, 2019 rates would likely be down significantly more...likely nearly 20% instead of 6.3%:
With the 2019 Open Enrollment Period quickly approaching, I'm spending a lot of time swapping out the requested carrier rate changes from earlier this summer with the approved rate changes from state regulators.
Hawaii only has two carriers participating in the ACA-compliant individual market: HMSA and Kaiser, which requested rate increases of 2.72% and 28.6% respectively back in August. With a roughly 57/42 market share split, this resulted in a weighted average rate increase of 13.8%, which would likely have been closer to 3.8% if the ACA's individual mandate penalty hadn't been repealed.
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
When I last posted about 2019 ACA-compliant individual market premium changes in Tennessee back in August, I noted that premiums statewide had gone from dropping 5.7% to dropping 10.8% on average after the Trump Administration first stated that they were going to unnecessarily "freeze" the ACA's Risk Adjustment fund transfers in response to a lawsuit ruling only to reverse themselves a week or so later and state that they were going to go ahead and process RA fund transfers after all.
In other words, the Trump Administration once again deliberately caused a panic across the industry only to "save" the industry from the very threat which they had posed in the first place.
In any event, here's what I thought the Tennessee's premium situation looked like when the dust settled:
Back in August, Blue Cross Blue Shield of South Carolina, the only carrier offering policies on SC's individual insurance market, asked for a 9.2% average premium rate increase for 2019 statewide. This consisted of 9.3% for their most popular plans (which cover over 200,000 South Carolinans) and 6.9% for 6,800 BlueChoice plan enrollees (BlueChoice is only available off-exchange).