OE6

2018 MIDTERM ELECTION

Time: D H M S

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it very clear that yes, they'd be lowering rates even further if not for the ACA's individual mandate penalty being repealed: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:

CMS Administrator Seema Verma is difficult to get a read on. On the one hand, she glories in trashing the ACA every chance she gets while happily endorsing nearly every effort to undermine or sabotage it, including repeal of the individual mandate, slashing the marketing and outreach budgets and so forth. Last year she was even busted trying to (effectively) blackmail the insurance carriers at large by offering to push through CSR reimbursement payment in return for them supporting the GOP's Obamacare repeal bill.

At the same time, she--like Trump's first HHS Secretary, Tom Price--also seems to have a soft spot for one particular type of ACA improvement program: Reinsurance.

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.

In my Tennessee 2019 rate filing analysis last month, I noted the good, the bad and the ugly:

  • The good news was that average unsubsidized 2019 ACA individual market premiums were expected to drop by about 5.7% after years of double-digit rate hikes.
  • The bad news was that due specifically to various types of deliberate sabotage by the Trump Administration and Congressional Republicans (primarily repeal of the individual mandate and expansion of #ShortAssPlans), that 5.7% drop was still a good 12 points or so higher than it otherwise would have been.
  • The ugly news was that due specifically to the Trump Administration's utterly unnecessary decision to freeze Risk Adjustment fund transfers in response to a lawsuit out of New Mexico, 2019 premiums would be hundreds of dollars higher still than they should have been for Blue Cross Blue Shield of Tennessee's 113,000 enrollees:

UPDATE: As noted in the comments below, it looks like Anthem won't be expanding to cover the entire state after all. Even so, this is a major improvement in the situation.

Every year, Virginia is the first state out of the gate with their preliminary healthcare premium rate changes for the following year, posting the initial rate requests in early May. For 2019, it originally looked like the carriers were asking for a statewide average increase of 15.2%, but I later corrected this to 13.4%.

However, these were just preliminary numbers. The requests still have to go through the rate review process, and the carriers often make other changes as well before the final deadlines pass.

Annnnnnnnd finally, the least-populated state of them all...which also happens to be suffering from the highest average monthly premiums for unsubsidized individual market enrollees: Wyoming.

There's only a single carrier in the Equality State (seriously...that's their motto; who knew?), Blue Cross Blue Shield. They're actually looking to lower rates by just a smidge (0.25% on average).

However, once again, the Urban Institute projected that there'd be roughly an 18.6% increase factor due to the ACA's individual mandate being repeale and short-term & association plans being expanded by the Trump administration.

Assuming just 2/3 of that to play it safe, that still means that unsubsidized enrollees would have been looking at roughly a 12% drop in their 2019 premiums without those measures...a difference of over $120/month, or a whopping $1,400 more apiece next year. Ouch.

The most noteworthy thing about West Virginia's 2019 filings that I can see is that CareSource is expanding their state coverage from 10 counties to 35 counties, and the confirmation that West Virginia will remain one of the few states sticking with a Broad Load CSR strategy for reasons unknown next year (the state insurance commissioner might change their tune, however, now that CMS has done a complete 180 degree turn and has officially come out in favor of Silver Switching).

In any event, the statewide average premium hike appears to be around 14.9%...but once again, much of this is due to the ACA's individual mandate being repealed and Trump opening the floodgates on #ShortAssPlans.

At $843/month, West Virginia has one of the highest average monthly premiums in the country...and instead of only going up nominally next year, thanks to #ACASabotage, unsubsidized enrollees will likely have to pay a whopping $1,300 more apiece next year.

South Dakota has two ACA indy market carriers, Avera and Sanford. The relative enrollment market shares are based on last year's numbers. The 14.4% #ACASabotage impact assumes 2/3 of the Urban Institute's projections to err on the side of caution.

THe average unsubsidized SD indy market enrollee pays $624/month this year; instead of that dropping by around $68/month, it's expected to increase by $22...for a total monthly difference of $90.

Assuming that's accurate, this means unsubsidized SD residents will be paying over $1,000 more apiece next year than they'd otherwise have to.

North Dakota was one of only two states (the other one was Vermont) which didn't allow their insurance carriers to add any additional premium load into their 2018 rates to account for Donald Trump's cut-off of Cost Sharing Reduction (CSR) reimbursement payments.

In direct response to this, Medica Health Plans dropped out of the ND on-exchange individual market this year to avoid taking the CSR hit. They hung around the off-exchange market, however, and therefore still have about 600 enrollees in the state.

As a result of this, my estimated impact of ACA sabotage efforts by the Trump Administration and Congressional Republicans has to include the factors from both 2017 and 2018: Cost-Sharing Reduction cut-off (9%) as well as Mandate Repeal and Short-Term Plan expansion (13.8%).

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.

Nebraska is about as simple as it gets--there's only one carrier offering ACA individual market plans. Unfortunately, they've redacted the combined average rate change request between their two plan entries, so all I can do is split the difference and assume around a 1% average increase.

The Urban Institute projected that Nebraska rates would see a whopping 20.4 percentage point increase due to #MandateRepeal and #ShortAssPlans, which are both referenced in Medica's filing. Since they don't get more specific than that, I'm assuming 2/3 of Urban's estimate, or a 13.6% increase.

Unsubsidized Nebraska enrollees are currently paying an average of $854/month, so if accurate, that's a difference of around $116/month or nearly $1,400 for the year. Ouch.

Mississippi is pretty easy: Only two carriers. I have no idea what their relative market share is (the enrollment data along with a lot of other stuff is redacted in their filings), but in this case it really doesn't matter because both of the carriers are requesting nearly identical rate changes anyway...which is to say, just about no change whatsoever.

The Urban Institute projected that #MandateRepeal and #ShortAssPlans would add a 17.2 percentage point rate hike factor in Mississippi. I generally knock 1/3 off of their estimates to err on the side of caution (11.4%), but given Ambetter specifically stating that they didn't add any increase to account for #ShortAssPlans (why?? interesting!), I'm shaving off a bit more and assuming a flat 10% impact.

This means that unsubsidized Mississippi enrollees would likely have saved a good $800 apiece next year without Trump/GOP efforts to undermine the ACA this year.

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