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Wyoming health insurance marketplace: history and news of the state’s exchange

Individual market premiums declining again in 2022; Open enrollment ended January 15, 2022

Image: Terri Cage / stock.adobe.com

Key takeaways

Wyoming exchange overview

Wyoming uses the federally run exchange, so residents enroll through Healthcare.gov. During the open enrollment period for 2021 coverage, 26,728 Wyoming residents enrolled in coverage through the exchange, which was a record high for Wyoming. Nearly 6,800 more enrolled during the COVID/American Rescue Plan enrollment window that ended August 15, 2021.

After several years of Blue Cross Blue Shield of Wyoming being the only insurer offering individual major medical coverage in Wyoming, Mountain Health CO-OP joined Wyoming’s market, statewide, for 2021. Mountain Health CO-OP (also called Montana Health CO-OP), one of the original ACA-created CO-OPs, already offered coverage in Idaho and Montana, and now offers plans in all three states.

All of the plans available for sale in Wyoming’s exchange are PPOs, which is unusual; insurers in many states have switched to EPOs and HMOs, and some states have no PPOs for sale at all (although that trend has started to reverse itself a bit, with some areas of the country gaining new PPOs for 2022). But both BCBSWY and Mountain Health CO-OP are offering only PPOs.

The Wyoming Department of Insurance published a notice in October 2021 reminding residents about the upcoming open enrollment period (and the overlapping open enrollment window for Medicare beneficiaries), and cautioning residents to “be especially cautious of off-exchange plans that seem too good to be true” (referring to non-ACA-compliant plans such as short-term coverage; off-exchange plans from Blue Cross Blue Shield of Wyoming or Mountain Health CO-OP are fully compliant with the ACA, although subsidies aren’t available if the plans are purchased off-exchange).

Wyoming premiums are higher than most of the rest of the country, but the ACA’s income-based premium subsidies keep coverage affordable for most enrollees. And because the cost of cost-sharing reductions was added to silver plan premiums starting in 2018, some enrollees who receive premium subsidies can get Bronze plans (and sometimes, Gold plans) for very low – in some cases, zero – after-subsidy premiums (and that was true before the American Rescue Plan increased the size and availability of the subsidies; net premiums are even lower now that the ARP has been implemented).

For 2021, Blue Cross Blue Shield of Wyoming reduced their average premiums by 10%, and for 2022, both insurers implemented modest rate decreases. For perspective, the nationwide average rate change amounted to a slight increase in overall average premiums in 2021, and another small increase in 2022. So Wyoming’s premiums are slowly becoming less of a high-end outlier.

Wyoming does not have an effective rate review process, which means the federal government (CCIIO) is in charge of reviewing rates in Wyoming. That system does not give federal regulators the ability to deny rate requests; rather, they’re only able to say whether or not the rate request is actuarially justified.

Unfortunately for Wyoming residents living below the poverty line, the high cost of unsubsidized coverage means that the coverage gap is particularly harsh in Wyoming. Since the state has not accepted federal funding to expand Medicaid, residents with incomes below the poverty level are not eligible for subsidies, and Medicaid is not available for most of them either. Their only alternative is to pay full price for private insurance, which is particularly unrealistic in a state where the average full-price premium is among the highest in the country, at $870/month in 2021 (although this is considerably lower than 2020, when the average full-price premium in Wyoming’s marketplace was $967/month).

While 70% of Wyoming residents disapprove of the ACA in general, 55% support Medicaid expansion according to a recent poll conducted by the University of Wyoming. The issue was reconsidered multiple times in light of the COVID-19 pandemic, but lawmakers rejected it. So a coverage gap continues to be the reality in Wyoming. But the Build Back Better Act, under consideration by Congress in the fall of 2021, would provide premium subsidies for people in the coverage gap, allowing them to obtain robust, premium-free coverage in the marketplace.

When can I enroll in health insurance in Wyoming?

The open enrollment period for 2022 coverage ran from November 1, 2021 to January 15, 2022. Outside of open enrollment, a qualifying event is necessary to enroll or make changes to your coverage.

Learn more in our comprehensive guide to open enrollment.

Which health insurance carriers offer 2022 coverage in the Wyoming marketplace?

Two insurance companies offer individual/family plans in Wyoming’s marketplace, and both have statewide coverage areas:

  • Blue Cross Blue Shield of Wyoming
  • Mountain Health CO-OP (Montana Health CO-OP)

How much does health insurance cost in Wyoming?

As described below, full-price premiums in Wyoming decreased fairly significantly for 2021, and are decreasing again for 2022, although they’re still among the highest in the nation. But very few people pay full price. Even before the American Rescue Plan made premium subsidies more widely available, almost 91% of Wyoming exchange enrollees were receiving premium subsidies for 2021. And because full-price premiums are high in Wyoming, premium subsidies are also very large.

That’s especially true now that the American Rescue Plan has enhanced premium subsidies. As an example, consider a 40-year-old living in Casper, Wyoming, with a projected income of $40,000 for 2022. They’ll qualify for a premium subsidy of $541 per month. After that subsidy is applied, they can select from among six plans that have no monthly premiums at all. And the other 11 plans have after-subsidy premiums that range from $20/month to $231/month, including some Gold plans that cost well under $100/month.

Average rates in Wyoming decreased slightly in 2019, grew slightly in 2020, and decreased significantly in 2021. So with the decrease for 2022, rates have decreased in Wyoming’s marketplace in three of the past four years. Wyoming’s average premiums were the highest in the country in 2019, although they dropped to second-highest as of 2020 (and appear likely to keep that position in 2022).

In the early years of ACA implementation, Alaska had the most expensive premiums, at least in terms of the cost of the second-lowest-cost silver plan in each area. But Alaska has since implemented a reinsurance program that has reduced premiums significantly. As a result, the average pre-subsidy premium in Alaska’s exchange is projected to be $723/month in 2022 — still higher than most states, but quite a bit lower than Wyoming’s $834/month average premiums. As described below, the Wyoming House passed a reinsurance bill in 2019 in an effort to reduce premiums for people who don’t get premium subsidies, but it died in the Senate.

Since full-price premiums in Wyoming are so much higher than the national average, the “subsidy cliff” was particularly problematic in the state, leaving some people with household income a little above 400% of the poverty level with no realistic coverage options. But the American Rescue Plan has eliminated the income cap for subsidy eligibility in 2021 and 2022, meaning that people with income above 400% of the poverty level can qualify for premium subsidies if the benchmark plan would otherwise cost more than 8.5% of their household income.

2022: Third average rate decrease in four years

For 2022, according to the federal rate review page (ratereview.healthcare.gov), both of Wyoming’s marketplace insurers have decreased their average premiums:

  • Blue Cross Blue Shield of Wyoming: Average decrease of 2.22%
  • Mountain Health CO-OP/Montana Health CO-OP: Average decrease of 5.98%

Enrollment numbers are redacted so we don’t have a weighted average rate change, but it’s clear that overall average premiums are decreasing in Wyoming for 2022.

When we talk about overall average rate changes, however, we have to keep in mind that they only reflect how full-price premiums are changing, and that they don’t account for the fact that a person’s rates will increase each year based on their age, even if their insurer doesn’t change its average premiums at all.

Most enrollees in Wyoming’s exchange receive premium subsidies, which offset the majority of the cost of their coverage. The subsidies are decreasing somewhat for 2022, due to the overall decrease in premiums. So although average rates are decreasing, the average enrollee is not likely to see a net decrease in premiums, since the subsidies are also getting a bit smaller.

Here’s a look at how premiums have changed in previous years in Wyoming’s exchange since plans became available in 2014:

  • 2015: Average increase of 5%. In 2015, when plans were still available from both BCBSWY and WINhealth, a Commonwealth Fund analysis found that rates in Wyoming’s exchange were an average of 5% higher in 2015 (compared with 2014) for a 40-year-old non-smoker. The NY Times Upshot pegged the increase in benchmark plan premiums in Wyoming at 7% or more, although the Kaiser Family Foundation showed the average benchmark plan rate in Wyoming increasing by just 1.6% for 2015.
  • 2016: Average increase of 6%. By 2016, Blue Cross Blue Shield of Wyoming was the only insurer in the state’s individual market. They increased their average rates by about 6% that year. WINhealth had proposed a rate increase of 13.37%, but they shut down at the end of 2015. Time insurance also offered plans outside the exchange in Wyoming in 2015, but they announced in June 2015 that they would exit the individual market nationwide, and would not participate in the 2016 open enrollment period.
  • 2017: Average increase of 8%. The average rate increase for Blue Cross Blue Shield of Wyoming’s individual market plans was fairly modest for 2017, especially compared with the national average that year, which was about 25%. BCBSWY’s average rate increase for exchange plans was 8.18% for BlueSelect plans without pediatric dental and 7.85% for BlueSelect plans with pediatric dental.
  • 2018: Average increase of 48% for on-exchange plans. 2018 was the first year that insurers had to account for the fact that the federal government was no longer reimbursing them for the cost of cost sharing reductions (CSR, sometimes called cost-sharing subsidies). BCBSWY added the cost of CSR to silver on-exchange plans, and created slightly different off-exchange silver plans that didn’t include the cost of CSR in their premiums. So Blue Cross Blue Shield of Wyoming had separate average rate increases for their off-exchange and on-exchange plans in 2018. Off-exchange, the average rate increase was 39%, with a range of 27.5% to 45.7%. But on-exchange, the average premium increase for 2018 was 48.2%, with a range of 25.9% to 83.6%. BCBSWY’s rate filing noted that “the premium rates for silver plans sold through the FFM would have been significantly lower if CSR funding were appropriated by the Federal government.” Average pre-subsidy premiums in the Wyoming exchange were the second-highest in the country in 2018, at an average of $973/month, according to CMS data. Only Iowa, with an average of $988/month, had higher average pre-subsidy rates. Although the overall rate increase was severe, the addition of CSR costs to silver plan rates and the resulting increase in premium subsidies means that people who get premium subsidies and buy bronze or gold plans gained access to more affordable coverage starting in 2018 (the subsidies are so large that bronze and even gold plans are sometimes free after the subsidy).
  • 2019: Average decrease of 0.27% for on-exchange plans. The cost of cost-sharing reductions (CSR) was once again being added to silver on-exchange rates for 2019 in Wyoming, and BCBSWY’s rate filing again indicated that “the premium rates for silver plans sold through the FFM would have been significantly lower if CSR funding were appropriated by the federal government.”For on-exchange plans, the average premiums for BCBSWY plans was 0.27% lower in 2019. And for off-exchange plans, the average decrease was 0.12%. For 2019, Wyoming had the highest average pre-subsidy premiums, at $960/month.
  • 2020: Average increase of 1.6%. For 2020 coverage, Blue Cross Blue Shield of Wyoming filed an overall average rate increase of 1.6% for their ACA-compliant individual market plans, which were implemented as-filed. Average pre-subsidy premiums in Wyoming were the second-highest in the country in 2020, at $956/month (West Virginia’s were higher, at $984/month). But subsidies continue to be much larger than they were prior to 2018, with free or very low-cost plans available to enrollees with modest incomes. For people who don’t qualify for subsidies, however, coverage can be unaffordable (for those whose income is just a little above the subsidy-eligibility cutoff, it’s useful to understand how pre-tax contributions to retirement accounts and/or a health savings account might bring total household income into the subsidy-eligible range).
  • 2021: Average rate decrease of 10%. For 2021 coverage, Mountain Health CO-OP joined the exchange in Wyoming, offering coverage statewide, bringing added plan choice and competition to the state’s insurance market. And Blue Cross Blue Shield of Wyoming implemented an average rate decrease of about 10% for 2021. This made coverage more affordable for Wyoming residents who don’t receive premium subsidies, although it also reduced the size of the average subsidies that most Wyoming exchange enrollees receive. Subsidies fluctuate based on the cost of the benchmark plan; if it becomes less expensive, the subsidies decrease as well. The average benchmark premium also decreased by 10% in Wyoming for 2021. (Note that the American Rescue Plan has significantly increased the size of premium subsidies for 2021 and 2022; it was enacted in March 2021, but the extra subsidies are retroactive to January 2021 for people who have been enrolled in an exchange plan since the beginning of the year).

Enrollment in Wyoming’s exchange

A record-high 26,728 Wyoming residents enrolled in coverage through the exchange during the open enrollment period for 2021 coverage.

Here’s a look at how many people enrolled in private plans through Wyoming’s exchange during open enrollment for each year since coverage became available in 2014:

  • 2014: 11,970 people enrolled. This was the fourth lowest in the country, but Wyoming has the smallest population in the US.
  • 2015: 21,092 people enrolled.
  • 2016: 23,770 people enrolled. All former WINhealth enrollees had to switch to Blue Cross Blue Shield of Wyoming for 2016, as Winhealth stopped offering coverage at the end of 2015. Enrollment grew from 2015 to 2016 in all but one county in Wyoming. Only Fremont county (Lander is the county seat) experienced an enrollment decline, with a 267-person drop in enrollment. Wyoming consumer advocates believed that was likely due to the federal government ruling that the Northern Arapahoe Tribe is a large employer and is thus required to offer health insurance to its full-time employees. As a result, some of the tribe’s employees may have switched from exchange plans to group coverage offered by the tribe.
  • 2017: 24,826 people enrolled. This was a 4% increase over 2016’s enrollment. In the majority of the states that use HealthCare.gov, enrollment peaked in 2016 and declined a little more each year. But in Wyoming, enrollment grew again for 2017, just as it had in each of the previous years.
  • 2018: 24,529 people enrolled — the first time that Wyoming’s exchange experienced a decline in enrollment. Across all states that use HealthCare.gov, average enrollment was about 5% lower in 2018, so Wyoming’s 1% enrollment decline was much less significant than other states experienced. And it came on the heels of an enrollment increase in 2017.
  • 2019: 24,852 people enrolled. This was a new record high for Wyoming. That came despite the elimination of the ACA’s mandate penalty at the end of 2018 and the Trump administration’s decision to reduce funding for HealthCare.gov’s marketing and enrollment assistance, and to expand access to non-ACA-compliant plans.
  • 2020: 24,574 people enrolled.
  • 2021: 26,728 people enrolled.

Wyoming had just one exchange insurer since 2016, but gained a second as of 2021

BCBSWY had been the only carrier offering coverage in Wyoming’s exchange (and the entire individual market, including off-exchange) since 2016, after WINhealth stopped offering coverage at the end of 2015. But for 2021, Mountain Health CO-OP joined Wyoming’s market, offering coverage statewide. The CO-OP already offered plans in neighboring Montana and Idaho, and has expanded their coverage area to include Wyoming.

WINhealth announced in late 2015 that they would exit the individual market at the end of that year (at that point, they were still planning to continue to offer group plans. The decision to exit the individual market was triggered by the shortfall in risk corridors payments. WINhealth found out on October 1, 2015 that they would not receive $4.4 million they were due under the risk corridors program (nationwide, insurers were shorted about $2.5 billion in risk corridors payments that year, and a total of about $12.5 billion over the three years the program was operational; the Supreme Court ruled in 2020 that the federal government must pay the money to insurers).

But Wyoming’s then-Insurance Commissioner Tom Glause noted that WINhealth’s decision “did not come as a surprise to the Department [of Insurance],” as they were already aware of the financial challenges WINhealth had been facing prior to the risk corridors shortfall.

And on October 21, 2015 the other shoe dropped when WINhealth was placed in receivership by the Wyoming Department of Insurance. They ceased sales of new plans at that point, and in January 2016, a Laramie County District judge signed an order to liquidate the company.

In the ensuing years, the Wyoming Department of Insurance had discussions with several out-of-state carriers about the possibility of them entering the Wyoming market at some point. In the spring of 2016, Melody Health Insurance Canopy Health Insurance had announced its plan to offer health insurance in the Wyoming and Nevada exchanges – limited to the Cheyenne and Las Vegas metro areas – for 2017. But the Wyoming Insurance Department confirmed in August 2016 that Canopy had been unable to get licensed in Nevada, which was the first step towards getting their Wyoming license.

As a result, they were not able to get licensed in Wyoming, and have never offered coverage in the Wyoming exchange. Blue Cross Blue Shield of Wyoming continued to be the only insurer offering plans in the Wyoming exchange from 2016 through 2020, although Mountain Health CO-OP has brought competition to the state’s market once again.

Wyoming House passed a reinsurance bill in 2019, but Senate killed it

Following in the footsteps of several other states — including Alaska, which shares many insurance dynamics with Wyoming — the Wyoming Department of Insurance worked in 2018 on a 1332 waiver proposal to seek federal funding for a reinsurance program. The proposal needed state legislative support before it could be submitted to the federal government, and although the Wyoming House passed a reinsurance bill (HB 85) with nearly unanimous support in early 2019, the measure died in the Senate.

Lawmakers in the Senate were concerned about the 1% assessment that the measure would have imposed on health and disability insurers in the state. That assessment was expected to raise about $9 million per year in state funding, but that would have been dwarfed by the federal “pass-through” funding that the state would have received under the terms of the 1332 waiver they would have proposed if the legislation had been enacted.

Reinsurance works by covering a portion of high-cost claims (the details vary across the states that have set up reinsurance programs, but they generally either reimburse insurers if they have patients with certain high-cost conditions, or reimburse a portion of claims that exceed a certain dollar amount; Wyoming’s legislation would have left the details up to the state insurance commissioner).

That results in lower premiums, because the insurers know that some of their risk is being absorbed by the reinsurance program. When premiums are lower, premium subsidies (funded by the federal government) are also lower, since they don’t have to offset such high premiums (for example, if the after-subsidy price needs to be $100, the subsidy amount will be lower if the pre-subsidy amount is $500, versus if it’s $350). In 2019, 92% of Wyoming exchange enrollees are receiving premium subsidies, so the federal savings would be considerable if subsidies were to be smaller.

By using a 1332 waiver, the state gets to keep the federal savings, rather than having the federal government keep the money. The state would then use the money to fund the reinsurance program, in addition to the $9 million that the state would have raised via the assessment on insurers. In Wyoming, the estimate was that the federal pass-through funding would have amounted to $60 million per year, so federal funds would have covered nearly 87% of the cost of the reinsurance program.

If the state had enacted HB 85 and moved forward with a 1332 waiver for reinsurance, it would have benefitted roughly 3,500 people who pay full price for individual market, ACA-compliant plans in Wyoming (both on-exchange and off-exchange). These individuals don’t qualify for premium subsidies. In most cases, that’s because their incomes exceed 400% of the poverty level, but they could also be affected by the family glitch, or purchasing coverage outside the exchange for some reason, where subsidies aren’t available.

For people who do qualify for premium subsidies, a reinsurance program would make little difference in their net premiums — their subsidies would have ended up being smaller, but that’s because the full-price cost of their plans would have been smaller as well. But for those who don’t qualify for any subsidies and are thus responsible for paying 100% of their premiums, the projection was that a reinsurance program would have lowered their premiums by about 17%.

No DOI oversight for Direct Primary Care Practices

In early 2016, then-Governor Matt Mead signed SF49 into law, exempting direct primary care programs from Wyoming Department of Insurance regulations and oversight. That makes it easier for doctors to establish direct primary care practices, charging members a set monthly fee in return for whatever primary care the patient might need.

Particularly in states like Wyoming, where unsubsidized health insurance is much more expensive than average, and where the “subsidy cliff” is much more of an issue than it would be in places with lower premiums, direct primary care models can be an attractive alternative to higher-priced major medical health insurance. And like healthcare sharing ministries, direct primary care practices pose a potential threat to the stability and health of the regular insurance risk pool, since sicker applicants are more likely to gravitate to higher-priced – but much more comprehensive – ACA-compliant health insurance.

With that said, it’s important to note that direct primary care memberships only cover primary care. If a member needs care that involves hospitalization or treatment that cannot be provided in a primary care setting, the primary care membership will not provide any value.

Wyoming exchange history

Then-Gov. Mead announced in late 2012 that Wyoming would default to the federal health insurance exchange for 2014, with the possibility of moving to a state-run exchange at some unspecified future date.

In 2012, the Wyoming legislature passed a bill requiring a small committee to study the federal government’s implementation and operation of the exchange. The committee was to monitor how many state residents use the federal exchange, what problems they encounter, operating costs, and other factors in deciding whether to recommend the state eventually take over operations of the exchange. The committee held its first meeting in April 2013, but Wyoming has never seriously considered the possibility of running its own exchange.

Gov. Mead initially refused to expand Medicaid, but began supporting expansion as time went on. In November 2014, Gov. Mead and the Health Department presented lawmakers with a modified Medicaid expansion proposal, and the governor asked them to approve it. Although a Senate committee approved a modified version of Mead’s proposal, the full Senate rejected it. Medicaid still has not been expanded in Wyoming as of 2021, despite the availability of additional federal funding under the American Rescue Plan.

Wyoming health insurance exchange links

HealthCare.gov
800-318-2596

Wyoming Insurance Department
Provides consumer protection and support to Wyoming residents by investigating consumer complaints and resolving issues on insurance matters.
(307) 777-7401 / Toll Free: 1-800-438-5768 / [email protected]

State Exchange Profile: Wyoming
The Henry J. Kaiser Family Foundation overview of Wyoming’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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