ShortAssPlans

This is a pretty minor update, but I'm trying to lock in all of the approved 2019 rate changes as they come in. Last month, South Dakota's two carriers, Avera and Sanford, posted requested rate increases which I thought were 2.6% and 10.0% at the time. I also estimated their relative enrollment at around 27,000 and 4,000 enrollees apiece for market share calculations, which gave a statewide average increase of around 3.5%.

I checked the South Dakota Insurance Division website again today, and it certainly looks like the filings have been approved by the state insurance regulators...however, when I double-checked the filings themselves, it looks like they were actually slightly lower than I thought: 2.5% and 9.7% respectively.

In addition, I was able to find the hard enrollment numbers for each...the total is pretty close to what I had it at (29,180 vs. 31,000), but the splut is quite different. Insetad of Avera still having an 87% market share, it looks ike the split is more like 63/37 this year. Since Sanford is requesting a significantly higher increase than Avera, that means the weighted statewide average is higher as well...around 5.2% instead of 3.5%.

I posted Montana's preliminary/requested 2019 ACA indiividual market rate change requests back in late June. At the time, they were seeking average rate increases of 6.0% statewide, and I estimated that the GOP's repeal of the ACA's individual mandate penalty, combined with the Trump Administration's expansion of #ShortAssPlans, accounted for about 9.9 percentage points of that.

More recently, the state insurance commissioner's website published approved 2019 rate changes. The average increases have been sliced down slightly (from 6.0% to 5.7% on average), and I've lowered my estimate of #ACASabotage impact from 9.9% to 6% based on the lack of either factor being prominently mentioned in the actual carrier rate filings. If accurate that means rates would have been flat year over year on average in 2019 if not for those factors.

Unsubsidized Montana enrollees are paying an average of $637/month this year, so that's roughly a $38/month difference, or around $460 for the full year.

Back in July, I wrote about a lawsuit filed by twelve state Attorneys General against the Trump Administration over their attempt to vastly expand "Association Health Plans" as an alternative to ACA-compliant healthcare policies:

A group of 11 states and Washington, D.C., are suing the Trump administration in an attempt to roll back a regulation that allowed for the expansion of certain health plans that skirt ObamaCare regulations.

The lawsuit, led by New York Attorney General Barbara Underwood (D) and Massachusetts Attorney General Maura Healey (D), alleges that the Department of Labor violated the Administrative Procedures Act when it wrote a rule expanding access to association health plans.

Association health plans allow small businesses and other groups to band together to buy health insurance. The rule allows more groups to join together to form associations.

The move is part of a broader Trump administration effort to open up skimpier, cheaper plans as an alternative to ObamaCare plans.

This Just In...

Ready for Open Enrollment, Health Connector sets 2019 plans with lower premium increases, selects community organizations to provide in-person support to residents

Boston – September 13, 2018 – The Massachusetts Health Connector Board of Directors today approved 57 Qualified Health Plans from nine carriers for individuals and families, with new plan designs that create better value for members and premium increases that average under 5 percent from 2018.

Unfortunately, the press release doesn't specify what "under 5%" means, nor does it break that out by carrier/market share. I've put in a request for those details and will update this as soon as I hear back from them. They sent me the following chart, but this only includes enrollees earning between 300-400% of the Federal Poverty Level, which means the marketshare across the entire individual market is likely somewhat different. I'm assuming the 4.4% overall average applies to the entire market but could be wrong about that as well:

For months now, I've been trying to get people to understand that when it comes to sabotage of the Affordable Care Act, especially in terms of individual market premium increases, you have to include the impact of actions taken by Donald Trump and Congressional Republicans in BOTH 2017 and 2018, not just 2018 alone.

In 2017, the single largest factor in the ~28% average national unsubsidized premium increase for ACA plans was Donald Trump's cutting off of Cost Sharing Reduction (CSR) reimbursement payments to carriers. This alone accounted for fully half of the 2018 increase. However, there were other, smaller actions taken which added up to another 3% or so: Slashing the Open Enrollment Period in half, CMS slashing the marketing budget for the federal exchange down 90%, slashing the outreach/navigator budget down 40% and so on.

Iowa has only a single insurance carrier offering ACA-compliant individual market policies this year. Next year they'll have two, as Wellmark has decided to Hokey Pokey their way back onto the exchange again in 2019...but since they weren't around this year, there's no current policy premiums to measure any increase (or decrease) against.

That leaves Medica. Here's what they had to say about their 2019 rates back in June:

Medica, the sole carrier now selling individual health insurance policies in Iowa, plans to raise its 2019 premiums by less than a tenth as much as it did for 2018.

Medica raised its Iowa health insurance premiums by a staggering average of 57 percent for 2018. It was the steepest such health insurance increase in Iowa history. Company leaders said last summer they needed the higher premiums to stay in the market. But this time around, the Minnesota-based carrier is planning to raise Iowa premiums by an average of less than 5.6 percent, state regulators disclosed Wednesday.

 Back in June, Washington State delivered the bad news: They were expecting 2019 ACA-compliant premiums to increase by another 19.1% (due primarily to this year's sabotage of the law by Donald Trump and Congressional Republicans) on top of this year's 36% increase (10 points of which was due specifically to Trump's CSR reimbursement cut-off).

Today, Washington insurance commissioner Mike Kreidler announced the approved 2019 premium changes, and while the news certainly isn't great, it's not quite as bad as expected earlier this summer:

Hmmm...OK, this is rather curious.

New Mexico was one of the earlier states to post their initial, requested 2019 ACA individual market premium hikes back in June. At the time, the five carriers asked for rate increases ranging from a slight drop (-0.4% for Molina) to as high as an 18.5% increase for Presbyterian Health, which is currently only offering off-exchange policies this year. Based on their preliminary filings, New Mexico was looking at a weighted average increase of around 10.0% next year, which would have been more like 4% if not for this years sabotage efforts by Trump and the GOP (mandate repeal & expansion of #ShortAssPlans):

Normally at this point in the year I only do full rate hike write-ups for states when their approved rate changes are made public by insurance regulators. I'm making an exception for Texas, however, because my preliminary analysis of the statewide average premium changes back in June was missing a huge portion of the market--I only had around half the ACA individual market accounted for, and I repeatedly warned that the missing enrollment and rate change data could easily skew the statewide average higher or lower.

Well, it's early September now, and not only do I have access to pretty much all of the missing data now, some of the rate filings have changed significantly as well. At the time, I estimated Texas carriers as requesting average rate increases of just 1.5% overall, with them dropping around 10.6% if not for the ACA's individual mandate being repealed and Trump's expansion of #ShortAssPlans.

Back in April, I started an ambitious project which set out to track every legislative or regulatory measure taken by every state to counter, cancel out or mitigate sabotage of the Affordable Care Act by the Trump Administration and Congressional Republicans. It resulted in this color-coded spreadsheet, which lists dozens of bills, proposals, amendments and so on at various stages of completion.

The bad news is that project has proven to be too large for me to keep up with--there's simply too many bills, too many stages and too much other stuff going on for me to keep track of it all.

The good news is that the Center for American Progress (which has slightly more resources than I do) has launched their own version of this project, and it's very slickly done:

Hat tip to Louise Norris for the heads up about the Kentucky Dept. of Insurance issuing their final rulings for 2019 ACA individual market and small group policy premiums:

DOI Completes Review of Individual and Small-Group Health Insurance Rate Filings

The Kentucky Department of Insurance (DOI) announced today that it has completed its review of the individual and small-group insurance rates filed in the Kentucky market. The rates will be used to calculate insurance premiums in the 2019 benefit year.

Kentuckians in the individual market will once again experience changes in premiums and plan offerings. The rates that will be used reflect an average rate increase of 4.3 percent for Anthem Health Plans of Kentucky (Anthem) and 19.4 percent for CareSource. Since the actual premium charged will vary by individual and the plan level selected, some individuals may see a decrease in rates.

This just in from the Florida Office of Insurance Regulation...

OIR Announces 2019 PPACA Individual Market Health Insurance Plan Rates  

TALLAHASSEE, Fla. – The Florida Office of Insurance Regulation (OIR) announced today that premiums for Florida individual major medical plans in compliance with the federal Patient Protection & Affordable Care Act (PPACA) will increase an average of 5.2 percent beginning January 1, 2019. Per federal guidelines, a total of nine health insurance companies submitted rate filings for OIR’s review in June with final rate determinations due by August 22, 2018. 

Following OIR’s rate filing review, the average approved rate changes on the Exchange range from a low of -1.5 percent to a high of 9.8 percent. This information can be located in the Individual PPACA Market Monthly Premiums for Plan Year 2019 document available here.

When I first ran the preliminary 2019 ACA individual market rate filings for Virginia way back in May, I concluded that the average premium increase will be around 13.4%. However, a lot has changed since then.

For one thing, Virginia expanded Medicaid to 400,000 low-income residents, which should help improve the ACA risk pool and in turn knocked the average rate increase down by 2.2 points, to around 11.3%.

For another, Anthem made a last-minute decision to expand their coverage areas in the state dramatically, which also provides much-needed competition for Optima in the Charlottesville area, among others.

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