Implementing Health Reform. The end of the week is often a very active time on the Affordable Care Act regulatory front. Friday, March 11, 2016, was no exception. At the close of a very quiet week following the release of the 2017 Benefit and Payment Parameters Final Rule and 2017 Letter to Issuers the preceding week, the floodgates broke late in the day on March 11.
Marketplace Enrollment
March 11 brought two enrollment reports. The HHS Assistant Secretary for Planning and Evaluation (ASPE) released a Final Enrollment Report on plan selections and reenrollments for the full 2016 open enrollment period, with a state-level data addendum.
CMS also released on March 11 its final effectuated enrollment snapshot for 2015. This differs from the ASPE report in that effectuated enrollment figures count only those enrollees who have activated their policies by paying premiums. In addition, the effectuated enrollment report provides numbers as of the end of 2015, while the ASPE report covers the full 2016 open enrollment period, from November 1, 2015 through February 1, 2016.
2016 Open Enrollment Period Final Enrollment Report
The headline of the report is old news—12.7 million individuals selected or were reenrolled in marketplace plans during the 2016 open enrollment period.
This number is only 8.5 percent greater than the 11.7 million plan selections during the 2015 open enrollment period, but it must be remembered that a substantial number of 2015 enrollees are now in the Basic Health Plan programs in Minnesota and New York and that the 2016 numbers are net of plan cancellations while the 2015 numbers were not. The 11.7 million 2015 plan selections resulted in 10.2 million effectuated enrollments, but the 2016 effectuated enrollment numbers are likely to be higher. The 12.7 million also do not include 1.2 million individuals determined or assessed to be eligible for Medicaid or CHIP by HealthCare.gov.
About 4.9 million of the 12.7 million enrollees were new consumers while 7.8 were reenrolled. More than 3.5 million, 28 percent, were aged 18 to 34. Almost 10.5 million qualified for advance premium tax credits (APTCs).
Of the 9.6 million individuals who selected plans or were reenrolled in the 38 states that use the HealthCare.gov platform, more than 8.1 million (85 percent) qualified for APTCs, which average $290 per person per month and covered 73 percent of their gross premium, leaving an average net premium of $106 per month.
More than 3.9 million of those who were reenrolled through HealthCare.gov (70 percent) actively selected a plan, and 61 percent of these switched to a different plan than they had enrolled in during 2015. New plan selectors were more likely to enroll in a plan for under $100 than active enrollees, who in turn were more likely to do so than passive enrollees. Plan switchers were more likely to change insurers than to change metal level. Those who changed insurers within the same metal level saved on average $40 a month.
The proportion of consumers who selected a plan or were reenrolled early in the enrollment period (86 percent) was much higher than in 2015 (73 percent) and the proportion who enrolled in the final week of open enrollment (7 percent) was much lower than in 2015 (12 percent). This meant that many more enrollees had a full year of coverage.
The number of individuals who selected or were reenrolled in a plan who self-identified as Hispanic went up dramatically for 2016 but the number who self-identified as African Americans went down. It is important to note, however, that only a little more than a third of plan selectors or reenrollees list a racial identity. As was true in 2015, women outnumbered men 54 to 46 percent.
As has been true in previous years, the profile of plan selectors varies from state to state. New consumers constituted 48 percent of enrollees in Louisiana, Tennessee, and Texas but only 30 percent in Maine. About 91 percent of enrollees received financial assistance in Florida and 90 percent in Mississippi and Wyoming, but only 66 percent received financial assistance in New Hampshire. In Utah and Louisiana, 32 percent of enrollees were aged 18-34, but only 20 percent in West Virginia.
Final 2015 Effectuated Enrollment Snapshot
As of December 31, 2015, 8.8 million consumers had effectuated enrollment in the ACA marketplaces, 6.3 million in marketplaces served by HealthCare.gov and 2.5 million in the remaining state-based marketplaces. This was down slightly from CMS’s announced goal of 9.1 million effectuated enrollments at the end of the year, but is up 40 percent from the 6.3 enrollments effectuated at the end of 2014.
Of the 8.8 million enrollees, 7.4 million or 84 percent were receiving APTC and about 5 million or 56 percent were receiving cost-sharing reduction payments. 20 percent of enrollees were in bronze plans, 68 percent in silver plans, 7 percent in gold, 4 percent in platinum, and less than half a percent in catastrophic.
The 8.8 million final effectuated enrollment figure is down considerably from the 10.2 million effectuated enrollments at the beginning of 2015. The individual market has always been subject to considerable churn. It is likely that many of those enrolled at the beginning of the year obtained job-based coverage during the year as the job market continued to expand, while others likely became eligible for Medicaid or CHIP.
CMS also noted that 500,000 were dropped during 2015 because of citizenship or immigration data matching issues and another 1.2 million had their APTC and CSR adjusted because of data matching. As noted below, CMS is working on improving its data matching performance and it is to be hoped that fewer enrollments are lost to data matching problems during 2016.
Delaying The “2017” Summary Of Benefits And Coverage Template Until 2018
The tri-agencies—Treasury, Labor, and Health and Human Services–released a frequently asked question document stating that health plans and insurers that maintain an open enrollment period will be required to use the new summary of benefits and coverage template and associated documents beginning on the first day of an open enrollment period that begins on or after April 1, 2017 for plan and policy years beginning after that date. Plans and insurers that do not use an annual open enrollment period will be required to use the SBC template and associated documents for plan years beginning on or after April 1, 2017.
The Centers for Medicare and Medicaid Services issued a separate FAQ stating that qualified health plans should file with their states either the 2012 (current) SBC or the 2017 (new) SBC template as directed by their state regulators, but that it is expected state regulators will ask them to file the 2012 template. QHPs should use the 2012 coverage example calculator for plan and benefit filings with CMS and complete fields referring to the new “simple fracture” coverage example with the default value $0. HealthCare.gov will not display fields for 2017 that are included only in the 2017 template.
This is a major disappointment for consumer advocates who had worked on the SBC and had hoped that the agencies would stick with the January 1, 2017 implementation date they had initially promised. As it is, QHPs will not display vital information found in the 2017 template until the 2018 open enrollment period, not even for special enrollments after April 1, 2017. Only employer plans, grandfathered, and transitional plans that are not on calendar year schedules will see any changes for 2017. The “2017 template” has effectively become the 2018 template.
Counihan Address Enrollment Effectuation And Data Matching
Marketplace CEO Kevin Counihan published a post at the CMS blog on “Keeping Consumers Covered.” CEO Counihan notes that CMS has been working at improving the proportion of consumers who make a binder payment—and thus effectuate their enrollment—by reminding consumers earlier, oftener, and more clearly to make their binder payment and by working with insurers to reinstate consumers who have trouble with the payment process.
The post also addresses data matching issues that arise when CMS has difficulty verifying Social Security numbers or income. In 2017, coverage was terminated or premium tax credits adjusted for 1.7 million consumers due to data matching problems. The fact that data matching issues arise does not mean, of course, that applicants have falsified information on the applications. Data matching issues are often due to a typographical errors or to the fact that the data hub, which is supposed to verify information provided by consumers, is itself relying on outdated information.
In any event, CMS has improved online information to inform consumers more clearly when data matching issues are created and what information the consumers need to provide to resolve them. CMS has added functionality to ensure consumers do not generate new data matching issues year after year if they have already resolved the issue for a particular year. As of 2017, CMS has also established more appropriate income verification thresholds.
CMS has made improvements in its notice language to give consumers clearer guidance as to what documents to provide and created a resource guide to prevent and help resolve income data matching issues. CMS reaches out to consumers as many as fourteen times to make sure consumers provide the information they need to provide to resolve issues. CEO Counihan claims that these efforts are resulting in a reduction of data matching problems.
FAQs On Reconciling Cost-Sharing Reduction Payments
Finally, on March 11, 2016, CMS released at its REGTAP.info website two sets of frequently asked questions consisting of over 100 questions and answers. As described in an earlier post, QHP insurers that received estimated cost sharing reduction payments during 2014 and 2015 are supposed to reconcile these payments with those they were actually due during April of 2016. The FAQs address a wide range of mainly technical issues, but they demonstrate the complexity of the reconciliation process—indeed the complexity of providing subsidized health insurance.
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