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Wisconsin’s exchange remains among the most robust in the country, with 13 insurers offering plans for 2023 (there were 14 in 2022, but WPS Health Plan is leaving the exchange as of 2023).
The state implemented a reinsurance program in 2019 that helped to facilitate overall average rate reductions four years in a row, from 2019 through 2022.
Wisconsin has a federally facilitated marketplace/exchange, which means people shopping for individual and family health plans use HealthCare.gov to enroll (as opposed to a state-run website).
Former Gov. Walker had previously expressed a preference for a state-run exchange rather than a “one size fits all” federally operated exchange. In 2011, Walker used an executive order to create the Office of Free Market Health Care to plan for a Wisconsin exchange. Walker’s plan for a “free-market, consumer-driven approach” leaned heavily on an insurance marketplace implemented by former Gov. Jim Doyle. According to one state insurance expert, the only notable change proposed by Walker was to put the exchange online.
However, Walker showed a changed mindset in 2012, returning a $38 million federal grant and closing the Office of Free Market Health Care. In announcing his November 2012 decision to accept a federally operated exchange, Walker said the state would have no real control and much higher financial risk with a state-run exchange.
Wisconsin was one of only seven states with a federally facilitated marketplace that had at least ten carriers in 2014. But despite the robust competition, Wisconsin’s exchange rates were relatively high in 2014. The average premium for the lowest-cost bronze plan in Wisconsin in 2014 was $287, compared with $249 nationally.
Citizen Action of Wisconsin, a liberal-leaning group pushing for Medicaid expansion and a public option in the state, highlighted the very different ACA paths taken by Minnesota and Wisconsin, and placed some of the blame for Wisconsin’s high rates on the fact that the state ultimately took a hands-off approach to the exchange and also refused to accept federal funds to expand Medicaid (Wisconsin essentially has what amounts to a partial expansion of Medicaid, so there is no coverage gap in the state. But Wisconsin does not receive the enhanced federal funding that would be available if the state were to expand Medicaid as called for in the ACA).
Walker refused federal funding to fully expand Medicaid and before leaving office, he secured federal approval to impose a Medicaid work requirement in Wisconsin (which was never implemented; approval was revoked by the Biden administration in 2021). But Walker lost the 2018 election to Tony Evers, who wants to expand Medicaid and would prefer to go even further, with “BadgerCare for All.”
The open enrollment period for individual/family coverage runs from November 1 to January 15 in Wisconsin. Outside of open enrollment, a qualifying event is necessary in order to enroll or make changes to your coverage.
If you have questions about open enrollment, our comprehensive guide to open enrollment is a good resource.
For 2023, there are 13 insurers offering plans in Wisconsin’s exchange, down from 14 in 2022.
WPS Health Plan Inc. is leaving the exchange at the end of 2022, but will continue to offer off-exchange plans in Wisconsin (Wisconsin Physicians Service Insurance Corporation, an affiliated insurer, already only offered plans outside the exchange, and will continue to do so in 2023).
People with on-exchange 2022 coverage from WPS Health Plan Inc. will be able to transition to an off-exchange WPS plan if they like. But if they receive a premium subsidy and want to continue to receive it in 2023, they’ll need to switch to an on-exchange plan from another insurer during open enrollment.
Thirteen insurers offer individual/family plans in Wisconsin’s exchange for 2023:
In October 2015, less than a week before open enrollment began for 2016 coverage, Anthem Blue Cross Blue Shield announced that they would pull out of the Wisconsin exchange in three counties: Milwaukee, Racine and Kenosha, where nearly a quarter of the state’s population resides. Anthem also announced that they would significantly reduce the number of available plans in 34 other counties in the state.
Network Health joined the Wisconsin exchange for 2016, offering plans in seven counties: Calumet, Milwaukee, Outagamie, Ozaukee, Racine, Waukesha, and Winnebago. The plans were also available outside the exchange.
14 carriers offered plans in the Wisconsin exchange for 2017. Ambetter, United, Physicians Plus, and WPS (Arise Health Plan) exited the exchange at the end of 2016, but Children’s Community Health Plan and Aspirus Arise joined the exchange for 2017:
In 2018, Wisconsin still had one of the most robust exchanges in the country in terms of the number of participating insurers, but Anthem, Molina, and Health Tradition Health Plans all left the exchange at the end of 2017, resulting in about 75,000 people needing to select new plans for 2018.
Anthem only offered one off-exchange plan in one county in 2018 (Menominee County, which has a population of just 4,500 and is one of the poorest counties in the state; off-exchange plans are not eligible for premium subsidies, so participation in this plan has likely been extremely low). The continuation of off-exchange coverage in Menominee County prevented a full market exit, which means that Anthem has the option to return to the state’s full individual market — including the exchange if they wish to do so — at any point in the future. A full market exit would trigger a five-year lockout from the state’s individual market, per federal regulations that predate the ACA.
Molina announced in August 2017 that they would exit the exchange in Wisconsin (and in Utah) at the end of 2017. Their total enrollment in Wisconsin, which included people with Medicaid and Medicare, was 130,000, and the Milwaukee Journal Sentinel reported that about 55,000 of those people had coverage in the individual market (it’s unclear what percentage of that population had on-exchange coverage, but it’s likely the majority; Molina did not market their ACA-compliant plans off-exchange for 2017, although some of their individual market enrollees likely had grandmothered and grandfathered plans).
Molina explained that Utah and Wisconsin were among the states where their marketplace performance had been “most disappointing” and that during the second quarter of 2017, Molina had spent 128 percent of the premiums collected in the Utah and Wisconsin exchanges on medical care (for reference, the ACA requires insurers to spend at least 80 percent of premiums on medical care as opposed to administrative expenses, but an amount of 100 percent or more is clearly unsustainable, as it means that the insurer is spending more on claims than it’s collecting in premiums, with no room for administrative costs at all).
Health Tradition Health Plans exited Wisconsin’s entire individual market at the end of 2017. Based on Health Tradition’s 2017 rate filings, their membership in 2016 was fewer than 10,000 people. But all of their remaining individual market enrollees needed to select new plans for 2018.
Gunderson Health Plan Inc. offered plans in the Wisconsin exchange in 2017, but there were no rate filings for Gunderson for 2018 on ratereview.healthcare.gov. However, earlier in 2017 there was a multi-insurer merger/acquisition that involved Gunderson.
Although Gunderson plans did not appear in the rate filings for 2018, Unity Health Plans filings were submitted. Unity already offered plans in the exchange in 2017, and their website noted that they were affiliated with UW Health/UnityPoint as the on-exchange insurance entity. But the Gunderson/Unity group transitioned to marketing plans under the name Quartz, and Unity’s website now redirects to the Quartz site. Quartz plans will be available in the Wisconsin exchange for 2020, but not Gunderson or Unity plans.
As rate filings trickled in around the country in the spring and early summer of 2017, there were initially 82 counties nationwide that didn’t have any exchange plans filed for 2018. One of them was Menominee County, Wisconsin, where 47 people were enrolled in exchange plans in 2017, and where Molina had been the only insurer offering exchange plans in 2017. Security Health Plan eventually stepped in to provide coverage in the exchange in Menominee County in 2018.
Molina continued to offer one bronze plan off-exchange, in Shawano County in 2018. But the premium on that plan increased by 106.3 percent that year, and it was not actively marketed. But by continuing to offer the off-exchange plans, Molina avoided a full market exit and was able to rejoin the exchange for 2019. They offered silver and gold plans in seven counties in the exchange in 2019, and discontinued the off-exchange bronze plan that they had offered in 2018 in Shawano County (it really only served as a place-holder so the Molina would have the option to return to the exchange/individual market in 2019 or a future year).
2020 – 2022
WSP (Arise Health Plan) returned to the Wisconsin exchange for 2020, with plans available in rating area 11. This brought the total number of participating insurers to 14. All 14 carriers continued to offer plans in the exchange for 2021 and 2022, with various coverage area expansions.
WPS Health Plan Inc. confirmed that they will no longer offer marketplace plans in Wisconsin after the end of 2022. Their plans will continue to be available outside the exchange. The other 13 Wisconsin marketplace insurers continue to offer marketplace coverage in 2023.
Across all of Wisconsin’s individual market insurers, the approved weighted average rate increase amounts to 7.65% for 2023, which is slightly higher than the 7.2% weighted average rate increase the insurers initially proposed in the spring of 2022. Detailed filing data are available in SERFF and on Wisconsin’s rate review webpage.
When we talk about overall average rate changes in the exchange, it’s important to understand that this is not representative of how the average enrollee’s rates will change. Most people get premium subsidies, and their rate changes also depend on how much the subsidy amount changes from one year to the next. And the overall average rate changes don’t account for age-related premium increases (even if your insurer doesn’t change its average rates at all, your premium will still increase because you’re a year older; premium subsidies also grow to keep up with age-related rate increases).
For perspective, here’s a look at how premiums have changed in Wisconsin’s exchange in previous years:
During the open enrollment period for 2022 coverage, 212,209 people enrolled in private individual market plans through Wisconsin’s exchange. This reversed a four-year streak of declining enrollment, with the growth due in large part to the increased affordability created by the American Rescue Plan’s subsidy enhancements.
Here’s a look at QHP (qualified health plan) enrollment in Wisconsin’s exchange during open enrollment for each year that ACA-compliant coverage has been offered:
In March 2018, Wisconsin enacted SB770 (Act 138). The legislation directed the state to submit a 1332 waiver to CMS, seeking federal funding for a reinsurance program in Wisconsin (Democratic efforts to include amendments in SB770 calling for a Medicaid buy-in program and a “robust rate review” process were unsuccessful).
For the 2023 plan year, there are 17 states that have reinsurance programs.
Wisconsin submitted it’s 1332 waiver proposal to CMS in April 2018. The waiver proposal was approved by CMS in July 2018, providing federal funding for the state’s reinsurance program for five years, starting in 2019. The state’s portion of the reinsurance program cost would come, in part, from savings due to the fact that the health insurance provider fee was suspended for 2019. The money that the state didn’t have to spend to cover the fee for the state’s group health insurance program (for state employees) and Medicaid managed care plans would instead be diverted to help fund the reinsurance program.
Wisconsin received about $128 million in federal pass-through funding in 2019, and $142 million in 2020. Federal funding was higher in 2021 ($229 million) and 2022 ($182 million), due to the American Rescue Plan.
Because premiums are lower than they would otherwise have been without the reinsurance program, premium subsidies (paid by the federal government) are also lower, since they don’t need to be as large in order to make coverage affordable. The idea behind the pass-through funding is that the state gets to take the money that the federal government saves due to lower premium subsidies, and use it to fund the reinsurance program.
Under Wisconsin’s reinsurance program, the state picks up 50% of the cost of a claim once it reaches $50,000. The state continues to pay 50% of the cost until the claim reaches $250,000 (these parameters vary from one state to another, among the states that have implemented reinsurance programs).
For 2019 coverage, rate filings in Wisconsin were due in early July (before the federal funding for reinsurance had been approved), so insurers in Wisconsin had to submit two sets of rates for 2019 plans — one based on the reinsurance program being approved (with lower rates that reflect the decreased risk to insurers), and one based on the status quo, without reinsurance. Ultimately, the lower rates were implemented, since the federal funding was approved.
Governor Walker’s office initially stated that average premiums for 2019 would be 3.5% lower in 2019 than they were in 2018, due to the implementation of the reinsurance program. In October, they revised that to an average rate decrease of 4.2%.
Overall average premiums in Wisconsin’s individual market declined each year from 2019 through 2022, and the reinsurance program is one of the factors keeping rates stable. The reinsurance program is approved through 2023, and the state submitted an extension request in 2022 that would extend the program for another five years.
The day after House Republicans passed the American Health Care Act (AHCA), Ted Nickel, who was at that time Wisconsin’s Insurance Commissioner, voiced his support for the legislation. In a May 2017 MacIver Institute article, Nickel welcomed the potential return to high-risk pools under the AHCA, and waxed about the benefits of Wisconsin’s pre-ACA high-risk pool, the Health Insurance Risk-Sharing Plan (HIRSP), which closed once health plans in the private market became guaranteed-issue regardless of medical history.
Nickel stated that for three decades, HIRSP provided solid coverage to Wisconsin residents, and indicated that at least some of those residents are worse off under the ACA (it’s noteworthy that people who qualify for significant premium subsidies in the exchange are likely paying lower premiums now than they were under HIRSP, but not everyone qualifies for substantial subsidies).
HIRSP covered roughly 24,000 people in the pre-ACA days when health insurance was medically underwritten in the private market, making it among the largest high-risk pools in the nation. And premiums were only about 20 percent to 30 percent higher than standard rates. That’s much better than most states’ high-risk pools, however, as high-risk pools typically had rates that were at least 50 percent higher than standard rates, and in some states, they were double the standard rates.
Governor Walker initially indicated that Wisconsin would be open to pursuing an AHCA waiver to eliminate some of the ACA’s consumer protections, which would have created an opportunity to reinstate HIRSP (the AHCA would have allowed states to opt-out of the ACA’s essential health benefits requirements; they would also have been allowed to let insurers charge premiums based on applicants’ medical history if the applicant had a gap in coverage during the prior year). But by the next day, after significant backlash over the potential evisceration of protections for people with pre-existing conditions, Walker appeared to backtrack on his position, saying that the state was “not looking to change” the current pre-existing condition protections.
All of that is a moot point, since the AHCA was never enacted. But it did highlight the health care reform positions of Wisconsin’s governor and insurance commissioner under the Walker administration. Governor Evers appointed Mark Afable as the state’s new Insurance Commissioner in January 2019.
As outlined in the 2017 Benefit and Payment Parameters, Healthcare.gov implemented a new protocol for 2017 that allowed the exchange to automatically re-enroll people whose 2016 carrier would no longer be offering any plans in the exchange for the coming year. But the state of Wisconsin— along with Nebraska — objected to the idea that Healthcare.gov would automatically pick a new plan (for enrollees who didn’t make their own plan selection) if their 2016 carrier was exiting the exchange.
Governor Walker and Insurance Commissioner Nickel (who was elected president of the National Association of Insurance Commissioners in December 2016) argued that the government does not have the right to force people into contracts with insurance carriers, or to direct people to one carrier over another. They also noted that as far as they were concerned, the proposal to automatically re-enroll people in plans from different carriers essentially amounted to selling health insurance without a license, which is not permitted in Wisconsin (or any other state, for that matter).
The Wisconsin Office of the Insurance Commissioner issued a press release in which they informed consumers how to opt-out of HealthCare.gov’s auto re-enrollment. Consumers could, of course, simply select a new plan by December 15 in order to avoid auto re-enrollment. But if they did not wish to continue to have coverage through the exchange, they could also log back into the exchange by December 15 and follow the steps to opt-out of auto re-enrollment (this is available to all HealthCare.gov enrollees in every state; it’s not specific to Wisconsin, but Wisconsin officials were vocal in letting their residents know about the opt-out feature)
On October 31, 2016, the day before open enrollment began, Nickel published a bulletin for insurers in Wisconsin, reiterating the fact that the state considerd HealthCare.gov’s automatic re-enrollment to be in violation of Wisconsin insurance law, but noting that the automatic re-enrollment would happen anyway, for up to 37,000 Wisconsin residents (many of them likely returned to the exchange to pick their own plans or opt-out of auto re-enrollment prior to mid-December, and were thus not automatically re-enrolled in plans selected by the exchange).
The October 31 bulletin laid out some guidelines for insurers to follow in the event that they received enrollments from HealthCare.gov that had not been initiated by the consumer (ie, that were automatic re-enrollments). Insurers that followed the guidelines did whatever they could to inform the consumers of the plan selection and gain consumer consent to enroll in the plan. By doing so, the carriers remained in compliance with Wisconsin insurance guidelines.
Wisconsin is one of the states that has an ACA-created CO-OP. Common Ground Healthcare Cooperative received federal loans to get up and running, and has been offering health insurance in Wisconsin since the beginning of 2014. Initially, there were 23 CO-OPs offering plans in 25 states. But only three are still operational as of 2022; Common Ground is one of them.
Common Ground Healthcare Cooperative lost money in 2014 — as did all but one of the CO-OPs. Their claims exceeded premiums by almost $44 million, and they enrolled more than two and a half times as many people as they had expected in 2014. All carriers that ended up with higher-than-expected claims were supposed to get risk corridor payments to help cushion the losses, but HHS announced in October 2015 that payments would be just 12.6% of the amount due. This threw several CO-OPs into financial crises, and Insurance Commissioners across the country had to make some tough decisions regarding the financial viability of the CO-OPs. But Common Ground survived.
Of the 11 CO-OPs that were still operational at the start of 2016, seven had closed by the end of 2017. Common Ground was among the four that remained operational. Although they lost nearly $17 million in the first half of 2016, they secured a capital infusion from an undisclosed source in September 2016 that allowed them to remain financially viable heading into 2017.
Common Ground’s average premiums increased by 63% in 2018. But for 2019, Common Ground decreased its average premiums by nearly 19%, indicating a new level of stability for the insurer. For 2020, Common Ground again decreased premiums, this time by more than 9%. Their rates decreased by more than 6% for 2021, and by nearly 6% for 2022. But they proposed an overall average rate increase of more than 11% for 2023. The CO-OP had almost 47,000 members as of 2021.
In September 2015, Wisconsin State Senator Chris Larson and State Rep. Debra Kolste announced the introduction of new legislation (AB359) that would have required Wisconsin to utilize a robust rate review process, much the same as many other states. Among other things, the legislation would have required the Insurance Commissioner to hold public hearings on proposed rate increases over ten percent, and would also have given the Insurance Commissioner the ability to deny rate hikes that aren’t justified by claims costs.
The legislation noted that “current law prohibits premium rates from being excessive, inadequate, or unfairly discriminatory”, and the state does have an outside actuary that reviews the rates. HHS also reviews proposed rates that include a premium increase of 15% or more (this threshold used to be 10%). But Larson and Kolste’s bill would have given the Wisconsin Insurance Commissioner far more regulatory oversight for health insurance premiums. However, it was considered unlikely that the bill would pass in the state’s Republican-dominated legislature; indeed, by mid-April 2016, the legislation was dead.
Wisconsin Office of the Commissioner of Insurance
Assists consumers who have purchased insurance on the individual market or who have insurance through an employer who only does business in Wisconsin.
(800) 236-8517 / [email protected]
State Exchange Profile: Wisconsin
The Henry J. Kaiser Family Foundation overview of Wisconsin’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.
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