- The open enrollment period for 2022 coverage will run from November 1, 2021 through January 15, 2022.
- UnitedHealthcare rejoining Alabama’s exchange for 2022.
- Average proposed rate changes for 2022: 7% increase for BCBSAL and 15% decrease for Bright (plus a look back at rate changes in prior years).
- Short-term health plans can be sold in Alabama with initial plan terms up to 364 days.
- 2021 enrollment increased by about 5% from 2020 enrollment, and is also higher than 2019 enrollment.
- Alabama’s exchange had only one insurer in 2017, but Bright Health joined as of 2018 in the Birmingham area (the exchange had three insurers in 2015 and 2016).
- Since 2018, the cost of CSR has been added to premiums for silver plans sold in Alabama’s exchange. This means plans at other metal levels are particularly inexpensive for some subsidy-eligible enrollees.
Alabama exchange overview
Alabama uses the federally facilitated marketplace, which means residents enroll in exchange plans through HealthCare.gov.
Blue Cross Blue Shield of Alabama was the only health insurance carrier offering plans in the Alabama exchange in 2017, and they already insured the majority of the state’s exchange enrollees prior to 2017, when there were multiple insurers offering coverage. But since 2018, residents in the Birmingham area have been able to choose from two different insurers in the exchange, as Bright Health now offers plans in that area. And for 2022, UnitedHealthcare will also join the exchange in Alabama, bringing total insurer participation to three.
2016 was the first year that Alabama participated in the rate review process for ACA-compliant plans (for 2017 coverage). Prior to that Alabama did not have an effective rate review process, so the federal government handled rate review for Alabama. The federal government still conducts rate review for Oklahoma, Texas, and Wyoming, but Alabama has joined the majority of the states that have an effective rate review process (Texas will have an effective rate review process as of 2022, when rates for 2023 coverage are being reviewed).
Alabama has not expanded Medicaid, so there’s a coverage gap in the state. Alabama could close the gap by accepting federal funding to expand Medicaid; the federal government would always 90% of the cost to do so, and as a result of the American Rescue Plan, the federal government would provide two years of additional federal Medicaid funding if the state were to expand coverage.
As the federal poverty level increases, the lower-end income requirements for premium subsidy eligibility also increases, potentially trapping more people in the coverage gap. For 2021, a single person must earn at least $12,760 in order to qualify for premium subsidies in Alabama (although this requirement does not apply in 2021 if the person receives unemployment compensation for at least one week during the year; in that case, the person is eligible for premium subsidies regardless of their actual income). For 2022, the minimum income for a single person to receive premium subsidies in the Alabama exchange is $12,880.
A 2020 analysis by the Robert Wood Johnson Foundation indicated that if Alabama were to expand Medicaid, the state’s uninsured rate would drop by 43% — the largest decline that any of the remaining non-expansion states would see if they all expanded Medicaid.
Which insurers offer coverage in the Alabama marketplace?
As of 2021, there are two insurers that offer exchange plans in Alabama. Both will continue to offer coverage in 2022 as well, and will be joined by UnitedHealthcare (UnitedHealthcare previously offered coverage in Alabama’s exchange, but exited at the end of 2016):
- Blue Cross Blue Shield of Alabama (plans available statewide)
- Bright Health (plans available in the Birmingham area)
- UnitedHealthcare (new for 2022)
When can I enroll in health insurance in Alabama?
Open enrollment for 2022 health plans will begin November 1, 2021, and will continue until January 15, 2022. Coverage will take effect January 1, 2022, as long as you enroll by December 15, 2021. Enrollments in the final month of the enrollment period will have coverage effective February 1, 2022.
The open enrollment period is an excellent opportunity to take advantage of the American Rescue Plan’s subsidy enhancements, which will still be in effect for 2022.
Learn more in our comprehensive guide to open enrollment.
You may still be able to enroll in coverage for 2021 if you experience a qualifying life event, or if you’ve received unemployment compensation at any point in 2021.
How are premiums changing in Alabama's exchange for 2022?
According to ratereview.healthcare.gov, Alabama’s insurers have proposed the following average rate changes for 2022:
- Blue Cross Blue Shield of Alabama: 7.15% increase
- Bright Health: 15.5% decrease (on the heels of a 22% increase in 2021)
- UnitedHealthcare: New for 2022, so no applicable rate change
The Alabama Department of Insurance has published a summary of the proposed rate changes for each specific plan that the insurers offer.
Average rate changes are calculated before premium subsidies are applied, and 95% of Alabama exchange enrollees receive premium subsidies. Subsidies are larger and more widely available for 2021 and 2022, thanks to the American Rescue Plan.
For perspective, here’s a look at how premiums have changed in Alabama’s exchange in previous years:
- 2021: Average increase of 5.3%. BCBSAL, which has the lion’s share of the market, increased premiums by an average of 5%. Bright’s increase was an average of 22%, but their filing indicated that they only had about 3,800 enrollees (versus 168,113 for BCBSAL). So the overall weighted average increase was about 5.3% for 2021.
- 2020: Average increase of 3.3%. Bright Health increased average premiums by about 9 percent, but Blue Cross Blue Shield of Alabama, which has most of the enrollment, only increased average premiums by 3.5 percent. The overall weighted average increase amounted to 3.3 percent.
- 2019: Average decrease of 2%. Both of the Alabama exchange insurers implemented 2019 rates that were lower than their 2018 rates. Bright Health had an average rate decrease of 15.55%. And Blue Cross Blue Shield of Alabama had an average rate decrease of 0.5% (ranging from a decrease of 3.8% to an increase of 3.9%, depending on the plan). These rate changes were approved as proposed for both insurers, and amounted to a weighted average decrease of about 2 percent. Both insurers noted in their rate filings that they expected increased morbidity (ie, a less healthy population, and thus premiums that are higher than they would otherwise have been) as a result of the elimination of the individual mandate penalty after the end of 2018, and the expansion of short-term health plans and association health plans. So although the insurers decreased their average premiums in Alabama in 2019, they would have decreased them even more if the individual mandate penalty had remained in place and if short-term and association health plans hadn’t been expanded by the Trump Administration.
- 2018: Average increase of 15.6% (as described below, the bulk of the increase applied to silver plans, due to the Trump Administration’s decision to stop funding cost-sharing reductions; Alabama’s insurers have continued to add the cost of CSR to silver plan rates in subsequent years).
- 2017: Average increase of 36%. Blue Cross Blue Shield of Alabama was the only insurer offering plans for 2017, and their average rates increased by 36%. 2016 was the first year that the state took part in the rate review process for ACA-compliant plans (for 2017 coverage); in previous years, the federal government handled the review process, as Alabama did not have an effective rate review process. That changed in the spring of 2016 however, and the state collaborated with HHS to ensure that the rates and plans filed for 2017 were in compliance with ACA requirements. Although, like many other states, Alabama regulators do not have the power to reject rate increases or prevent them from taking effect.
- 2016: Average increase of 24.4%. In 2016, there were three insurers offering plans in Alabama’s exchange. Humana’s average rate increase was just under 9%, Blue Cross Blue Shield of Alabama’s was 28%, and UnitedHealthcare’s was 24.5%.
- 2015: Average increase of 3%, according to a study by the Commonwealth Fund.
Insurer participation in Alabama’s exchange over the years
Historically, Alabama’s health insurance market was considered one of the least competitive in the nation. And it remains a market dominated by Blue Cross Blue Shield of Alabama, which is currently the only insurer offering plans in most of the state (Bright Health also offers coverage in the exchange, but only in the Birmingham area).
Humana and Blue Cross and Blue Shield of Alabama sold individual health insurance through the federal marketplace in Alabama for 2014. UnitedHealthcare joined the exchange for 2015, offering plans in all 67 Alabama counties. Those three insurers continued to offer plans in Alabama’s exchange in 2016, but Blue Cross Blue Shield still covered the majority of the state’s exchange enrollees.
And United and Humana both left the Alabama exchange at the end of 2016. The Alabama Department of Insurance confirmed that both carriers’ exits applied to the entire individual market in the state, so individual market United and Humana plans were not available on or off-exchange in Alabama as of 2017.
So enrollees with United or Humana coverage in 2016 had to switch to BCBSAL plans for 2017 if they wanted to remain insured. For perspective, Humana had 15,226 individual market members in Alabama in 2016, including both on and off-exchange. UnitedHealthcare expanded to offer coverage in all 67 counties in Alabama starting in 2015, and their total exchange enrollment in the state was 20,488 in 2015. That was about 12% of the total in 2015, up from just 5% in 2014.
Although BCBSAL was the state’s lone exchange insurer in 2018, Bright Health joined in the Birmingham area in 2018 and has continued to offer coverage there. And for 2022, UnitedHealthcare is returning to Alabama’s exchange, bringing the total number of insurers to three.
[hio_question question="How many people have enrolled in health plans through Alabama's exchange?"]169,119 people enrolled in private individual market plans through the Alabama exchange during open enrollment for 2021 coverage. This was an increase of more than 5% from the year before, and was also higher than 2019’s enrollment. Here’s a summary of enrollment numbers in Alabama’s exchange over the years:
- 2014: 97,870 people enrolled
- 2015: 171,641 people enrolled
- 2016: 195,055 people enrolled
- 2017: 178,414 people enrolled
- 2018: 170,211 people enrolled
- 2019: 166,128 people enrolled
- 2020: 160,429 people enrolled
- 2021: 169,119 people enrolled
As was the case in the majority of the states that use HealthCare.gov, peak enrollment came in 2016 in Alabama. Enrollment in most states that use HealthCare.gov then declined until 2020, but increased somewhat in 2021 — the same pattern we see in Alabama. The declines are due to a variety of factors, including the Trump administration’s decision to sharply reduce funding for exchange marketing and enrollment assistance, and the shorter open enrollment period that started to be used in the fall of 2017. In addition, confusion about the status of the ACA, particularly the individual mandate, played a role in the declining enrollment, as did much higher premiums in 2017 and 2018 for people who don’t get premium subsidies (people who do get premium subsidies are mostly protected from the impact of rate increases).
Cost of CSR added to silver on-exchange plans starting in 2018
Blue Cross Blue Shield of Alabama confirmed in June 2017 that they would continue to offer coverage in all counties in the state in 2018. Their rates increased by an average of 36 percent in 2017, although subsidies increased enough to offset that for the vast majority of Alabama’s exchange enrollees. And for 2018, they implemented a rate increase less than half that size, despite the assumption (which proved correct) that cost-sharing reductions (CSR) would not be funded by the federal government, as well as an assumption that the individual mandate wouldn’t be well enforced (the mandate is still being enforced in 2018, but the penalty was eliminated after the end of 2018). So although rate hikes were steep for 2017, the rate increase for 2018 would have been in the low single-digits if it weren’t for the uncertainty caused by the Trump Administration.
For 2018, Bright Health joined the Alabama exchange, but only in the Birmingham metropolitan area.
The following average rate increases were implemented for 2018 in the Alabama exchange:
- Blue Cross Blue Shield of Alabama (statewide): 15.6% average rate increase, although the bulk of the rate increase applied to silver plans. The approved rate increases were based on the assumption that cost-sharing reductions (CSR) would not be funded in 2018, and that the individual mandate would not be well enforced.
- Bright Health (Birmingham metropolitan area): New to Alabama, so there is no applicable rate increase. But a revised rate filing submitted in August noted that the cost of CSR has been added to silver on-exchange plans for 2018 (but not to off-exchange silver plans)
The rate increases were largest for silver plans because those are the plans to which cost-sharing reductions (CSR) apply. BCBSAL’s rate filing noted that “the proposed rate increases for the QHP silver plans are much higher than the proposed rate increases for the remainder of the plans.” The filing indicates that the rate increases range from 2 percent for Blue Cross Select Gold to 21.2 percent for Blue Value Silver. The rate filing also notes that two BCBSAL plans —Blue Secure Silver and Blue HSA Gold — would be sold only off-exchange. So the Blue Secure Silver plan did not have the cost of CSR added to the premiums, since nobody on that plan would have CSR benefits, as they’re only available on-exchange (Blue HSA Gold also did not have the cost of CSR added to premiums, as it’s a gold plan and also off-exchange).
The Trump Administration announced in October 2017 that CSR funding would end immediately, but BCBSAL and Bright Health had already made that assumption in their premiums for 2018. Since the government has stopped reimbursing insurers for the cost of CSR, the insurers have to collect higher premiums for those plans to offset the cost. But the vast majority of enrollees (including virtually everyone who receives CSR plans) are receiving premium subsidies, which fluctuate to keep pace with changing premiums.
The CSR approach that Alabama’s insurers have taken — adding the cost of CSR to on-exchange silver plans, while also making off-exchange silver plans available without the cost of CSR added to their premiums — is the approach that protects virtually all enrollees. People who qualify for premium subsidies are protected from the rate hike, because the cost of CSR is added to silver plans, and premium subsidies are based on silver plan rates (specifically, the second-lowest-cost silver plan in each area). So the subsidies keep silver plan rates fairly consistent from one year to the next, and the larger-than-normal premium subsidies can also be used to cover even more of the cost of plans at other metal levels. This makes bronze plans particularly inexpensive for people who get premium subsidies, and can also result in some gold plans being priced lower than some silver plans, after accounting for subsidies.
People who aren’t eligible for premium subsidies can purchase plans at other metal levels that don’t have the cost of CSR added to the premiums. If they want a silver plan, they can purchase one that’s only marketed off-exchange (no premium subsidies are available off-exchange, so again, this is only a logical choice for applicants who are 100 percent certain that they won’t qualify for premium subsidies).
Insurance executive compensation is a secret in Alabama
Under a law passed in Alabama in 2015 (SB147, which became Act Number 2015-227 when it was signed into law in May), insurance executive compensation in Alabama is now kept confidential, and is not subject to open records requests, freedom of information requests, or subpoena.
The legislation was sponsored by Slade Blackwell (R, Mountain Brook), and passed with nearly unanimous support. It applies to all insurance companies in the state, but it primarily impacts Blue Cross Blue Shield — by far the dominant carrier in the state. That’s because national carriers, including Humana and UnitedHealthcare (the other two exchange carriers in Alabama) have to report executive compensation to the IRS and the SEC. But Blue Cross Blue Shield of Alabama (a state-based carrier) does not file with the SEC and doesn’t have to disclose executive compensation to the IRS.
Before Act 2015-227 took effect, it was public knowledge that the top ten executives at BCBSAL saw their compensation double from 2011 to 2013.
Reporter John Archibald described the new law as “royal treatment” for BCBS of Alabama, and it’s certainly concerning that executive compensation for the carrier is now protected from the public eye. But residents of Alabama are still protected by the ACA’s medical loss ratio, which requires carriers to spend at least 80 percent (85 percent in the large group market) of premiums on medical care and “quality improvements,” with administrative expenses — including executive compensation — coming out of the remaining 20 percent (15 percent in the large group market).
Alabama exchange history
The federal government operates the health insurance marketplace in Alabama, based on then-Gov. Robert Bentley’s November 2012 decision against a state-run marketplace. Bentley cited annual operating costs of up to $50 million as his reason for opting for a federally operated exchange, although it should be noted that the federal government does not run its exchange for free — CMS charges a fee equal to 3.5 percent of premiums (proposed to drop to 3 percent of premiums as of 2020) in states that rely on the federally-run exchange.
The decision against a state-run exchange came somewhat as a surprise. While the Republican governor consistently opposed many provisions of the Affordable Care Act, he repeatedly expressed support for a state health insurance exchange. He supported exchanges during his campaign for governor, and as governor, he used an executive order to establish the Alabama Health Insurance Exchange Study Commission. In November 2011, that commission unanimously recommended Alabama implement a state-run exchange. However, bills to establish a state-run exchange failed to pass in both the 2011 and 2012 sessions.
Alabama has not expanded Medicaid. Former Gov. Bentley opposed Medicaid expansion, and his position became the subject of campaign ads, editorials, billboards, and websites during 2014. Late in 2014, Bentley reintroduced a discussion on Medicaid expansion. Bentley said his administration would explore options to obtain federal Medicaid funding for a state-designed solution with a work requirement for recipients. Conservative groups promptly accused Bentley of flip-flopping, but nothing had come of his Medicaid expansion talk as of 2017 when he resigned amid a scandal. His successor, Governor Kay Ivey, has rejected Medicaid expansion efforts since taking office in 2017.
An August 2014 study published by the Urban Institute showed the impacts of not expanding Medicaid. In terms of financial impact, the authors calculated that while Alabama would spend $1.08 billion to expand Medicaid over a ten-year period, the state is losing out on $14.4 billion in federal spending and state hospitals are losing $7.0 billion in reimbursement over the same period.
And from a humanitarian standpoint, a Kaiser Family Foundation analysis estimates that there are 127,000 Alabama residents in the coverage gap as a result of the state’s refusal to accept federal funding to expand Medicaid. These people are not eligible for Medicaid due to the state’s strict eligibility requirements, but they also aren’t eligible for ACA subsidies in the exchange because their incomes are under the poverty level.
Alabama health insurance exchange links
Alabama Department of Insurance – Health Insurance Reform Information Center
State Exchange Profile: Alabama
The Henry J. Kaiser Family Foundation overview of Alabama’s progress toward creating a state health insurance exchange.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.