Now that the Inflation Reduction Act (IRA) has surmounted the key hurdle of passing the Senate — and is expected to soon pass the House of Representatives as well — the Affordable Care Act exchange market is set for another late-season policy shift that could alter next year’s premium rates. However, experts tell AIS Health that the effect on carriers’ overall premium calculations won’t be as significant as the impact on consumers’ out-of-pocket insurance expenses.
Health Policy Experts Warn of Consequences If ARPA Subsidies Expire and Medicaid Redeterminations Resume
During the past two years, the number of people enrolled in Medicaid and marketplace plans has significantly increased thanks to legislation meant to help people as the COVID-19 pandemic continues. But millions of those people may lose their health insurance coverage in the coming months if those policies end, which could lead to difficult circumstances for them and the health care industry as a whole, according to health policy experts who spoke during a July 15 webinar sponsored by Alliance for Health Policy, a Washington, D.C., nonprofit.
As of March 2022, nearly 87.9 million people were enrolled in Medicaid or the Children’s Health Insurance Program, up from just over 71.2 million in February 2020, according to the Kaiser Family Foundation (KFF). Sara Collins, Ph.D., vice president for health care coverage and access at the Commonwealth Fund, noted that much of the increase could be attributed to the Families First Coronavirus Response Act (FFCRA).
Approximately 3 million people currently enrolled in the individual marketplace could lose coverage, and more would see premiums double if the Congress fails to extend the American Rescue Plan Act’s subsidies, which are set to expire at the end of this year.
ARPA lowers the share of income enrollees need to contribute toward premiums for households making between 100% and 400% of the federal poverty level, and it temporarily caps enrollees with income above 400% of the FPL from paying more than 8.5% of their income for a silver plan premium. If the subsidies expire, 8.9 million people would be allowed to remain in the marketplace but experience premium subsidy loss. An additional 1.5 million may lose subsidies entirely but choose to remain insured, according to an HHS projection.
UnitedHealth Group announced on July 15 that it would eliminate out-of-pocket costs for insulin and a few other medications for beneficiaries enrolled in fully insured plans. The managed care organization expects to implement the changes starting as early as Jan. 1, 2023, pending regulatory approval.
Health and drug policy experts who spoke with AIS Health, a division of MMIT, applauded UnitedHealth’s decision, and noted it would benefit patients who struggle to pay for medications and increase adherence. They also said the move could help United financially, as members are more likely to stay out of the hospital and have better long-term health, but they said it could lead to higher premiums for employers and employees. UnitedHealth did not respond to AIS Health’s request for comment on how the company would foot the bill for implementing the zero cost-share policy.
Premiums on the individual marketplace are set to increase by an average of 10% nationally, according to an analysis by the Kaiser Family Foundation (KFF) of the first batch of preliminary premium rate filings sent to state exchange regulators. The filings are just the first in several steps before carriers lock in rates for open enrollment for the 2023 plan year, and don’t represent the final price of those premiums. But experts tell AIS Health, a division of MMIT, that utilization and medical trend mean that substantive price increases are a certainty — even if Congress extends the American Rescue Plan Act’s (ARPA) enhanced premium tax credits, which are set to expire at the end of this year.
Researchers from the American Academy of Actuaries expect the most notable factors in 2023’s health insurance premium rate-setting will be COVID-19 variants, the expiration of enhanced premium subsidies in the individual marketplace, the resumption of Medicaid eligibility redeterminations, inflation and provider labor shortages — a combination of public health, policy and economic factors that represent the long tail of the COVID-19 pandemic.
The impact of COVID-19 is still difficult to model. New variants to the virus and regional outbreaks mean that plan-level analysis is fraught. But the cost of hospitalization and a consistent standard of care mean that plans have a useful base for modeling.
Centene Corp. revealed during its June 17 investor day that it plans to reduce by 65% the amount of office space it leases across the United States as a way to cut costs and appease employees who prefer working from home. Like many large employers, other health insurers have followed suit — or are considering doing so — as they adjust to an office environment that looks much different than was standard before COVID-19.
Several major insurance companies declined to discuss their office leasing plans when contacted this week by AIS Health, a division of MMIT. But most, if not all, are actively evaluating their real estate footprints, according to Dan Mendelson, the CEO of Morgan Health, JPMorgan Chase Co.’s health care arm.
Colorado received permission from the Biden administration on June 23 to go ahead with the final element of its so-called “public option,” the Colorado Option. Experts tell AIS Health, a division of MMIT, that the program’s design is likely to deliver more premium savings than Washington state’s public option — and that the savings could make their way to the commercial market, especially if Individual Coverage Health Reimbursement Arrangements (ICHRAs) make further inroads in the Centennial State.
Experts tell AIS Health that the Colorado Option is innovative and could produce substantial premium savings, in large part because it has aggressive premium reduction goals. Starting in 2023, premiums for Colorado Option plans must be 5% lower than 2021 premiums, ultimately resulting in 15% cuts in premiums in 2025. After that, starting in "2026 and each year thereafter" premiums may increase "above the premium in the previous year by no more than medical inflation, relative to the previous year," per a summary of the law from the state legislature.
Grappling with rising premiums, a tough labor market and COVID-fueled health challenges, plan sponsors are focusing on key benefits as they prepare for the 2023 benefits cycle. That includes a concerted focus on behavioral health services and health equity, working to improve telehealth access and implementing strategies aimed at managing the total cost of care.
As adverse mental health conditions have increased sharply during the pandemic, behavioral health solutions, such as expanded access via network design and an expansion of virtual channels, figure to be prominent among purchasers’ needs, according to purchasing experts and benefits consultants interviewed by AIS Health.
Health insurers will likely issue about $1 billion in medical loss ratio (MLR) rebates this year, according to data from the Kaiser Family Foundation (KFF) and Mark Farrah Associates. That amount is a drop from both 2020 and 2021, which set the all-time highs for MLR rebates disbursed since the Affordable Care Act came into effect. Experts tell AIS Health, a division of MMIT, that the dropoff in rebates is related to pandemic utilization and a more stable policy environment for the individual marketplace.
Health plans selling insurance on the individual, small group and fully insured large group markets are required to return any premium revenue that is not spent on care (or care quality improvements) to members.