END OF 2018 OPEN ENROLLMENT PERIOD (42 states)

Time: D H M S

Sabotage

Last winter and spring, you may recall that I crunched a ton of data to come up with my best estimates about just how many people were projected to lose their healthcare coverage at the Congressional District level in the event various versions of Affordable Care Act repeal/replacement bills were to be signed into law (the AHCA, BCRAP, ORRA and so forth). After the first couple of attempts, the folks over at the Center for American Progress took over much of the heavy lifting on my part.

CAP started breaking the numbers out, leaving me to separate them out into easily-sharable state-level infographics (I also added partisan info for each member of Congress, since every Democrat has been steadfastly opposed to each one of these bills, while just about every Republican has supported most of them so far).

 

Welp. There you have it.

It's not over yet, since the House of Representatives still has to vote on the bill again (either as is, or after hashing out the differences between the House and Senate versions of the bill), but assuming the final version of the bill includes mandate repeal and is indeed signed into law, this is what the ACA's 3-legged stool would look like when the dust settles.

Obviously I'll have much more to say about what happened last night soon, but for the moment I'll leave it at this.

 

(h/t to former CCIIO Director Gary Cohen for the reminder)

You've probably never heard of the Center for Consumer Information & Insurance Oversight (CCIIO)...

The Centers for Medicare & Medicaid Services’ Center for Consumer Information and Insurance Oversight (CCIIO), part of the Department of Health & Human Services (DHHS), provides national leadership in setting and enforcing standards for health insurance that promote fair and reasonable practices to ensure that affordable, quality health coverage is available to all Americans. The center also provides consumers with comprehensive information on coverage options currently available so they may make informed choices on the best health insurance for their family.

...but among other things, they're the folks who actually implement the ACA, including, among other things, HealthCare.Gov (I'm not sure if it's the same team that operates HC.gov or not...probably a lot of overlap between the two?).

Consumer Information and Insurance Oversight

Ensuring the Affordable Care Act Serves the American People

A few days ago I noted that I had seriously misunderstood the Congressional Budget Office's individual market premium projections in the event the ACA's individual mandate is repealed: Yes, it'd be ugly, but not nearly as bad as I thought, although they still expect up to 13 million people to lose coverage as a result.

Yesterday, the Center for American Progress did an analysis which broke out those 13 million by state...along with the impact on individual market premiums and the 25 billion in immediate Medicare cuts which the GOP's tax bill would implement.

While I have my own doubts about some of the CBO's assumptions, there can be no doubt that premiums would increase substantailly, millions of people would end up without healthcare coverage, and the $25 billion in Medicare cuts do appear to be locked in if the GOP's bill were to become law:

Me, just under a month ago:

Things were looking pretty dicey for two of Montana's three insurance carriers participating on the individual market the past few days. One of the three, Blue Cross Blue Shield, saw the writing on the wall regarding Cost Sharing Reductions (CSR) likely being cut off and filed a hefty 23% rate hike request with the state insurance department. The other two, however (PacificSource and the Montana Health Co-Op, one of a handful of ACA-created cooperatives stll around), assumed that the CSR payments would still be around next year and only filed single-digit rate increases.

I'm not going to speculate as to the reasons why they both did so when it was patently obvious that having the CSRs cut off was a distinct possibility, although I seem to recall the CEO of the Montana Co-Op said something about their hands being tied since CSR reimbursement payments are legally required, after all. Basically, it sounds like he was genuinely trying to avoid passing on any more additional costs to their enrollees than they had to.

Just taking a moment to pat myself on the back. Here's my final estimate of the average unsubsidized 2018 premium increases nationally, along with a rough breakout of the reasons for the increase:

With the 2018 Open Enrollment Period coming up just 5 days from now, it's time to put this to bed: After 6 months of painstaking research and analysis, I've compiled a comprehensive analysis of the weighted average rate changes for unsubsidized ACA-compliant individual market policies in 2018, including both the on- and off-exchange markets. It's already been confirmed by a different analysis by healthcare consulting firm Avalere Health, which used a completely different methodology to arrive at the exact same conclusion: The national average increase is between 29-30%, ranging from as low as a 22% average premium drop in Alaska (thanks to their successful reinsurance program) to as high as a painful 58% increase in Virginia.

With the 2018 Open Enrollment Period coming up just 5 days from now, it's time to put this to bed: After 6 months of painstaking research and analysis, I've compiled a comprehensive analysis of the weighted average rate changes for unsubsidized ACA-compliant individual market policies in 2018, including both the on- and off-exchange markets. It's already been confirmed by a different analysis by healthcare consulting firm Avalere Health, which used a completely different methodology to arrive at the exact same conclusion: The national average increase is between 29-30%, ranging from as low as a 22% average premium drop in Alaska (thanks to their successful reinsurance program) to as high as a painful 58% increase in Virginia.

With only 5 days to go before the launch of the 2018 Open Enrollment Period, time is rapidly running out for me to wrap up my 2018 Rate Hike Project. I started this, as I have for 3 years now, back in late early May with the very first requested rate changes out of Virginia, and have been tracking all 50 states as the summer and fall have passed, following every twist and turn of the insane repeal/replace circus in Congress, Trump's bloviating and blathering about "blowing things up" and "letting Obamacare explode", the last-ditch "Graham-Cassidy" sideshow and everything else, right up to and through Trump lowering the boom on cutting off CSR reimbursement payments.

I'm still missing final 2018 rate data for 6 states, but in the meantime I'm also doing some cleanup of some of the states I thought I already had final data for. Today both my home state of Michigan as well as Washington State released their official, approved increase tables.

Michigan's average is nearly identical to what it was before...it only dropped from 26.9%...to 26.8%.

However, I do give the Michigan Dept. of Insurance & Financial Services huge credit for making it incredibly easy for me to plug their data in. Look at that...they list all carriers, whether they sell on or off exchange, the exact average rate increases, and even include the number of affected enrollees, which is usually the hardest number for me to track down. Thanks, MI DIFS!!

When I ran the requested rate hike numbers for Kentucky in early August, it looked like the only 2 carriers participating in the individual market next year (CareSource and Anthem BCBS) were asking for pretty hefty hikes of around 30.8% on average...and that assumed CSR reimbursement payments would be made next year. If they aren't, based on the Kaiser Family Foundation's estimates, I tacked on an additional 13.8% for a requested average of 44.3%. Ouch.

Since then, the Kentucky DOI has posted the approved rates...and the final numbers aren't not too far off, I'm afraid to say:

Back in August, I posted a rough analysis of the requested rate increase situation for Wisconsin's individual market carriers. However, I cautioned at the time that I was missing the enrollment market share numbers for four of the carriers (Aspirus, Compcare, Wisconsin Physician Service and WPS), and therefore had to guess at how the rate hikes for those carriers would impact the statewide average. I estimated the numbers assuming CSR payments are made at 21.7%, and from that assumed the impact of CSR reimbursements not being made would be around 7.8 additional points being tacked onto the average.

A couple of weeks ago, the state insurance commissioner announced the approved rate increases. The good news is that I overestimated on the "CSRs paid" front. The bad news is that I underestimated on the "CSRs not paid" front: It's actually 20% and 36% respectively:

 

On November 10, 2016, at 4:30 in the morning, I was still in a bit of a dazed state trying to absorb the reality that a racist, misogynistic, xenophobic con-artist sexual predator moron was about to become the next President of the United States. We were 9 days into the 2017 Open Enrollment Period, and I realized that there was absolutely no way of knowing what sort of impact the election results might end up having on how many people would sign up for coverage.

My original, pre-OE4 projection was that it would come in anywhere between 13.5 - 14.0 million people, but I quickly realized that I'd have to drastically alter my thinking. How drastically? Well, I actually posted the following to give an idea of how deep into the unknown we were:

Up until a week ago, the possibility of Donald Trump pulling the plug on Cost Sharing Reduction reimbursement payments was a looming threat every day. While it hadn't actually happened yet, most of the state insurance commissioners and/or insurance carriers themselves saw the potential writing on the wall and priced their 2018 premiums accordingly (or at the very least prepared two different sets of rate filings to cover either contingency).

A few spread the extra CSR load across all policies, both on and off the exchange. This seems like the "fairest" way of handling things on the surface, but is actually the worst way to do so, because it hurts all unsubsidized enrollees no matter what they choose for 2018 and can even make things slightly worse for some subsidized enrollees in Gold or Platinum plans.

When I plugged in the requested rate hike numbers for New Jersey back in August, they averaged around 8.5% assuming CSR payments would be made, or around 21.6% if they aren't.

The approved rate increases for NJ were just released, and the numbers appear to be pretty close to that, if a bit higher: 9.9% and 22.0% respectively.

Truth be told, I only have the hard numbers for the exchange-based carriers...and even those aren't technically official; they come from this NJ.com article:

TRENTON -- New Jersey residents who bought their own health coverage from Horizon Blue Cross Blue Shield through the Affordable Care Act could pay an average of 24 percent more next year, according to state-approved rates released on Tuesday.

Horizon is one of three insurance companies in New Jersey participating in the Obamacare marketplace in 2018. But it is the most dominant, insuring 72 percent of the 244,000 individual policy holders this year.

I first looked at Rhode Island's proposed rate hikes back in early July. At the time, the average increase for the two carriers participating in RI's individual market was 10.5% assuming CSR reimbursement payments are guaranteed for 2018. If they weren't guaranteed, however, I estimated at the time that an additional 19 percentage points would be added into the mix, based on an estimate by the Kaiser Family Foundation.

However, I realized a little later on that I was misinterpreting KFF's analysis; they were referring to how much they estimated silver plans would go up due to the lost CSR funds, not all metal levels. Furthermore, for Medicaid expansion states (which includes Rhode Island) they estimated the average was only 15%.. Based on these factors, the impact across the board on Rhode Island should have only been around 10.3%.

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