Highlights and updates
- Open enrollment for 2020 coverage in Illinois will run from November 1 to December 15, 2019.
- Enrollment is open at any time for Illinois residents with qualifying events.
- Short-term health plans can be sold in Illinois with initial plan terms up to 364 days.
- Get Covered Illinois: A partnership exchange with the federal government.
- Insurers have proposed modest rate changes for 2020, with a mix of increases and decreases.
- As of 2020, state-regulated plans in Illinois will provide more robust coverage of mammograms.
- Enrollment down nearly 20% since 2016
- Five insurers are offering plans in 2019 and 2020 (plus a look back at how insurers participation has changed since 2014)
- 2018 rates reflected uncertainty at the federal level & lack of CSR funding
- BCBSIL left underutilized SHOP exchange at the end of 2017, but Health Alliance continues to offer SHOP plans.
Illinois exchange overview
Illinois operates a partnership exchange with the federal government; the state runs Get Covered Illinois, including a website, in-person assistance, and a help desk, and the federal government provides the IT platform — Healthcare.gov — that Illinois residents use to enroll in coverage or make changes to their plan. In January 2016, the Governor appointed Karen Woods, a former Blue Cross Blue Shield executive, to lead Get Covered Illinois.
Starting in August 2015, the Illinois Department of Insurance began administering Get Covered Illinois, and 15 staff positions were eliminated in the move to “streamline program processes, improve efficiency, and align services leading to increased access to health coverage for Illinoisans.”
Get Covered Illinois has minimal staff at this point, and the Trump Administration announced in mid-2017 that they would no longer fund community enrollment assistance programs in 18 cities across the country, including Chicago. The federal government also drastically reduced the advertising budget for HealthCare.gov.
All of this has left consumer advocates in Illinois scrambling to try to fill in the gaps and ensure that there is enough outreach and enrollment assistance available to consumers — a problem that was compounded by the fact that open enrollment was shortened in the fall of 2017, and the shorter schedule (November 1 to December 15) is slated to remain in place going forward.
Lawmakers in Illinois passed legislation that would have limited short-term health plans, but Governor Rauner vetoed it in August 2018. As a result, short-term health insurance can be sold in Illinois with an initial term of up to 364 days. At the discretion of the insurer, plans can also be renewed for a total duration of up to 36 months.
2020 health plans and rate changes
Open enrollment for 2020 health plans will begin November 1, 2019, and will end December 15, 2019, with all plans effective January 1, 2020. The Illinois exchange has five participating insurers, although they have localized coverage areas. The insurers have proposed the following average rate changes for 2020:
- Celtic Insurance Co. (Ambetter): An overall average rate decrease of 0.07 percent (a 1.04 percent decrease for plans that include dental and vision coverage, and a decrease of 0.01 percent for plans that don’t have dental and vision coverage).
- Health Alliance Medical Plans, Inc. (HAMP): An overall average rate decrease of 4.03 percent (7.87 percent decrease for HMO plans, and 2.31 percent decrease for POS plans). HAMP has 35,929 members in 2019
- Health Care Service Corporation, (HCSC, Blue Cross Blue Shield of Illinois): An overall average rate decrease of 0.02 percent.
- Cigna: An average rate increase of 5.8 percent.
- Gunderson/Quartz/Unity (new to Illinois in 2019): Overall average rate increase of 5.32 percent.
The proposed rates are still under review and have not yet been approved by the Illinois Department of Insurance.
In 2019, HCSC offers coverage statewide, and HAMP offers coverage in eight of the 13 rating areas in Illinois. But Celtic/Ambetter only offers plans in two rating areas, and Cigna offers plans in three rating areas (both carriers limit their coverage to the Chicago area). Gunderson/Quartz offers plans in four counties: Boone, Ogle, Stephenson, Winnebago.
Illinois will require more robust coverage of mammograms on state-regulated plans as of 2020
Illinois has enacted legislation (SB162) to expand on the scope of mammography coverage that must be offered at no cost to residents enrolled in state-regulated plans (self-insured group plans are regulated under federal law rather than state law, so state regulations don’t apply to them; most very large employers self-insure rather than purchasing commercial health insurance).
The new law takes effect in January 2020. It will require health plans to go beyond the federal preventive care mandate for mammography, which only requires insurers to cover—with no cost-sharing for the patient—screening mammograms (ie, when there is no cause for concern, and the patient is simply having a routine mammogram).
Under the new law in Illinois, insurers will have to continue to fully cover screening mammograms, but will also have to cover breast ultrasounds and MRIs for women with dense breast tissue or women whose doctor believes the ultrasound or MRI is medically necessary. In addition, insurers will have to fully cover (with no cost-sharing) diagnostic mammograms, which are used when an abnormality is detected in the breast, either during a screening mammogram or otherwise.
The Illinois law does include an exception for plans that are HSA-qualified and would lose their HSA-qualified status if they provided pre-deductible coverage for anything beyond what the federal government considers preventive care.
Illinois exchange enrollment: 2014-2019
As is the case in most states that use HealthCare.gov, enrollment in the Illinois exchange peaked in 2016 and has steadily declined since then; enrollment in the Illinois exchange is nearly 20 percent lower in 2019 than it was in 2016.
The lower enrollment can be attributed to a variety of factors, including shorter open enrollment periods in recent years, the Trump administration’s decisions to sharply reduce funding for exchange marketing and enrollment assistance, increasing premiums for people who don’t qualify for premium subsidies, the expansion of short-term health plans, and the elimination of the individual mandate penalty.
Here’s a look at how many people have enrolled (during open enrollment each year) in private individual market plans through the Illinois exchange over the years:
- 2014: 217,492 people enrolled
- 2015: 349,487 people enrolled
- 2016: 388,179 people enrolled
- 2017: 356,403 people enrolled
- 2018: 334,979 people enrolled
- 2019: 312,280 people enrolled
Premium changes in previous years
2015: ACA-compliant plans debuted in 2014, and premiums were mostly an educated guess. The Illinois Depart of Insurance summarized 2015 premium increases by metal level, with an average increase of 11 percent for the lowest-cost bronze plan, 2.6 percent for the lowest-cost silver plan, and 3.7 percent for the lowest-cost gold plan:
2016: According to the Illinois Department of Insurance, the average rate increase for the lowest-cost Silver plan in the Illinois exchange was 5.3% for 2016, and the average increase for the lowest-cost Bronze plan was 11.3%.
Blue Cross Blue Shield of Illinois imposed an average rate increase of 17.9 percent for individual market plans in 2016 (ranging from a 17.5 percent decrease to an increase of more than 49 percent). The new rates applied to 329,427 enrollees (including off-exchange). 80 percent of Illinois exchange enrollees had BCBSIL plans.
State-wide, the average benchmark (second-lowest-cost Silver plan) premiums were 6.1 percent more expensive in 2016 than in 2015, which meant average subsidies were higher too. But it’s noteworthy that in the Chicago area, a Kaiser Family Foundation analysis determined that the average benchmark premium was 7.9 percent less expensive in 2016 than it was in 2015. This appears to be due in large part to Celtic’s entry to the market and their relatively low premiums.
2016 rates were filed prior to the Court’s ruling in the King case, but the Illinois Department of Insurance had announced that if the subsidies were stuck down by the Supreme Court, carriers would have had two weeks from the date of the ruling to refile new (much higher) rates for 2016.
If that had happened, unsubsidized average premiums in Illinois would have increased from $336/month in 2015 to $504/month in 2016. For Illinois exchange enrollees who receive subsidies, the result would have been much more significant: Their premiums would have quadrupled from an average (after-subsidy) premium of $125/month in 2015 to $504/month in 2016.
2017: The Illinois Department of Insurance published details showing the average approved rate increases for 2017 based on metal levels, rather than specific to each carrier. Average rate increases for the lowest-cost plans at each metal level varied from 43 percent to 55 percent.
In October, HHS confirmed that the average second-lowest-cost benchmark plan in Illinois would increase in price by 43 percent in 2017 (before any subsidies are applied). That’s nearly double the 22 percent average increase across all the states that use HealthCare.gov. But in terms of actual dollar amounts, the average second-lowest-cost silver plan in Illinois (for a 27-year-old enrollee, before subsidies) was $298/month in 2017 — very much on par with the $296/month average across all HealthCare.gov states.
Celtic/Ambetter’s average rate increase for 2017 was 45 percent to 59 percent. Health Care Service Corporation (BCBSIL)’s average rate increase was 51.3 percent (BCBSIL had more than three-quarters of the individual market share in Illinois in 2016, and were the only insurer to offer plans state-wide in the exchange in 2017), Humana’s average rate increases was 46.3 percent, and Cigna was new to the exchange for 2017.
2018: The four insurers offering exchange coverage in Illinois in 2018 implemented the following average rate increases, which were approved by state regulators:
- Celtic Insurance Co. (Ambetter): Average increase of 43.1 percent, based on uncertainty regarding CSR funding (the funding was later eliminated altogether by the Trump Administration). The cost of CSR was added to silver plan rates, both on and off-exchange. Rate change applied to 36,030 members.
- Health Alliance Medical Plans, Inc. (HAMP): Average increase of 41.1 percent (rate included a factor to account for the “potential elimination” of the individual mandate and cost-sharing reduction funding). The cost of CSR was added to on-exchange silver plan rates. Rate change applied to 34,171 members.
- Health Care Service Corporation, (HCSC, Blue Cross Blue Shield of Illinois): Average increase of 16.6 percent (included a rating factor to account for “loosening of the individual mandate enforcement,” and “uncertainty regarding the continuation of CSR funding”) Rate change applied to 296,621 members, by far the largest market share of any of the Illinois insurers.
- Cigna: Average increase of 27 percent (rate change was based on the—correct—assumption that CSR would not be funded). Rate change applied to 26,993 members.
The Illinois Department of Insurance advised insurers to add an additional premium load to silver plans for 2018 to account for the possibility that cost-sharing reductions might not be funded, but they did not allow insurers to file two sets of rates simultaneously (one assuming cost-sharing reductions would continue to be funded, and one assuming they wouldn’t), as some other states did. They did allow insurers to file revised rates if necessary, and CMS gave HealthCare.gov insurers an extension on revising rates (as late as September 5) and committing to exchange participation (as late as September 27).
Ultimately, Celtic revised their rates sharply higher (to account for the potential CSR funding cut and the expected lack of enforcement of the individual mandate), but the other insurers had already accounted for those in their initial filings, and actually revised their proposed rates slightly downward later in the summer. Overall, the lack of federal funding for CSR accounted for a significant portion of overall 2018 rate increases in Illinois.
2019: In October 2018, the Illinois Department of Insurance published an analysis of on-exchange health plans for 2019, including a summary of how premiums would change and information on which insurers would be offering plans in each area of the state. Average rate changes across most of the state varied between a decrease of 5 percent and an increase of 5 percent.
As was the case in prior years, the report focused on rate changes by metal level:
- Premiums for the lowest-priced bronze plans in the Illinois exchange increased by 6 percent in 2019.
- Premiums for the lowest-priced silver plans decreased by 4 percent.
- Premiums for the second-lowest-priced silver plans decreased by 3 percent ( CMS pegged the decrease at 2.7 percent in Illinois). Note that the second-lowest-cost silver plan in each area is the benchmark plan, and is used to calculate premium subsidy amounts.
- Premiums for the lowest-priced gold plans decreased by 6 percent.
At the carrier level:
- Celtic/Ambetter decreased average rates by 3.77 percent (without adult dental/vision coverage) and 4.39 percent (with adult dental/vision)
- Health Alliance Medical Plans, Inc. (HAMP): increased rates by an average of 4.7 percent average increase. HAMP had 35,032 members in 2018
- Health Care Service Corporation, (HCSC, Blue Cross Blue Shield of Illinois): increase of 0.9 percent. HCSC offers a PPO throughout Illinois, and is the only insurer to do so.
- Cigna: 7 percent average increase
Illinois Department of Insurance Director Jennifer Hammer has noted that the market in Illinois is stabilizing, both in terms of the rate changes for 2019 and the fact that the number of insurers in the exchange was growing from four to five. But at ACA Signups, Charles Gaba estimates that average premiums in Illinois would have dropped by about 13 percent if the individual mandate penalty wasn’t being eliminated, and if the Trump Administration hadn’t taken action to expand access to short-term plans and association health plans (both serve to siphon healthy people out of the ACA-compliant risk pool, leading to higher premiums for the people who remain).
Lawmakers in Illinois tried to limit short-term plans in 2018 in an effort to stabilize the individual market, but Gov. Rauner vetoed their legislation, paving the way for the Trump Administration’s relaxed rules for short-term plans to take effect in October 2018. As of late 2018, the Illinois Department of Insurance had approved “quite a few” short-term and association health plans for sale in the state.
2014: Five insurers offered individual market plans in the Illinois exchange in 2014: Aetna, Health Care Service Corporation (Blue Cross Blue Shield of Illinois), Health Alliance, Humana, and Land of Lincoln (an ACA-created CO-OP).
2015: Time and IlliniCare joined the exchange for 2015, bringing the number of participating insurers to eight, but both insurers only offered plans for one year, exiting the exchange at the end of 2015.
2016: Time/Assurant announced in mid-2015 that they would exit the health insurance market nationwide at the end of the year, so their plans were not available for 2016.
But Aetna, Celtic, and Harken joined the market in 2016. Celtic is the sister company of IlliniCare. Aetna offered plans in the exchange in 2014 under the name Aetna Life Insurance Company, but exited for 2015. They returned for 2016 as a separate legal entity, Aetna Health Inc.
There were nine carriers offering a total of 290 plans for individuals in the Illinois exchange in 2016 (ten if you count Coventry as two separate carriers, which the Division of Insurance does). Three carriers — HCSC, Land of Lincoln, and Coventry — offered plans state-wide.
Health Care Service Corp (Blue Cross Blue Shield of Illinois) covers about 80 percent of the state’s individual market enrollees.
BCBSIL announced in September 2015 that they would not offer their broad PPO (Blue PPO) network for ACA-compliant plans in 2016.
With Celtic’s entry to the market, they were offering the lowest-priced plans in some areas. This was good news in terms of added competition, but bad news for people who kept their 2015 plans and then received smaller subsidies in areas where Celtic took over the benchmark spot with a premium lower than 2015’s benchmark rate. This was the case in Cook County, where Celtic’s low prices (and very limited network) meant that subsidies decreased for 2016.
There were significantly fewer plans available in Cook County for 2016, but the Department of Insurance noted that this was is primarily because “IlliniCare withdrew multiple plans that offered the same medical benefit packages with the only difference in coverage being the options to have adult dental and/or adult vision. This accounts for a reduction of 44 plans.”
The Department of Insurance confirmed that there are no platinum plans available in the individual market in 2016 in Illinois. There were 81 platinum plans available in 2015, up from 25 in 2014. But they had all been discontinued as of 2016. This has been a trend nationwide, as platinum plans have tended to have very low enrollment rates compared with the other metal levels.
2017: Aetna exited the Illinois exchange at the end of 2016, as was the case in 11 of the 15 states where they offered exchange plans in 2016. UnitedHealthcare also exited the exchange, and so did Harken Health, which had offered plans in the Chicago area in 2016 (Harken also left the exchange in Georgia; Illinois and Georgia were the only two states where Harken offered plans, and they had only joined the exchanges for the first time in 2016).
In 2016, there were two separate Coventry entities offering plans in the Illinois exchange: Coventry Health & Life Insurance Co. as well as Coventry Health Care of Illinois, Inc. The Illinois Department of Insurance confirmed that Coventry would not offer plans in the exchange in 2017.
So Harken, Aetna, Coventry, and UnitedHealthcare exited at the end of 2016, and Land of Lincoln Health was placed in liquidation in the fall of 2016, with coverage ending September 30, 2016 (details on the departures are below). But Cigna joined the exchange in the Chicago area for 2017. So the Illinois exchange had five carriers offering plans for 2017, down from nine in 2016.
2018: Humana, one of the five insurers that offered plans in the Illinois exchange in 2017, exited the individual health insurance market nationwide at the end of 2017. Illinois has 13 rating areas, and Humana offered coverage in 2017 in northern Illinois, in three full areas (5, 7, and 8) and in part of rating area 10.
Celtic, HAMP, HCSC (BCBSIL), and Cigna continued to offer plans in the Illinois exchange for 2018.
2019: Celtic, HAMP, HCSC (BCBSIL), and Cigna all continued to offer plans for 2019, and they were joined by newcomer Gunderson/Quartz/Unity.
Land of Lincoln CO-OP closed September 30, 2016
In July 2016, regulators at the Illinois Department of Insurance announced that they would be taking over Land of Lincoln Health—an ACA-created CO-OP—and establishing an orderly wind-down of the carrier’s business. Land of Lincoln plans were no longer for sale in Illinois as of July, and the CO-OP was placed in liquidation on September 29, with coverage for existing members ending on September 30, 2016. FAQs about the situation have been published on the Land of Lincoln Health site. The Illinois Life and Health Guaranty Association covered Land of Lincoln claims (beyond the insurer’s assets), but announced in 2018 that they would no longer accept any new claims for Land of Lincoln insureds or providers.
The state worked with HHS to implement a special enrollment period for Land of Lincoln’s 49,000 members so that they would be able to transition to new plans.
In Oregon and New York, when CO-OPs closed mid-year, other carriers in the state agreed to enroll the CO-OP members and credit them for the out-of-pocket costs they had incurred to that point in the year. But that did not happen in Illinois.
Blue Cross Blue Shield of Illinois — by far the largest insurer in the state’s individual market — said they would not be able to credit Land of Lincoln members for out-of-pocket costs they’ve already incurred in 2016 if the members switched to BCBSIL starting in October. The state noted that it did not have the power to force carriers to give transitioning CO-OP members credit for their out-of-pocket costs for the first three quarters of 2016, and no other carriers said they would do so. The result was that CO-OP members who had already incurred charges in 2016 had to start over again on their out-of-pocket exposure for the year as of October 1, under the new plan they selected. And then they had to start over again just three months later, on January 1, paying towards 2017’s out-of-pocket exposure.
In April 2017, Illinois regulators reached out to previous Land of Lincoln members, explaining that they could file claims against the liquidated assets of the CO-OP if they could demonstrate that they suffered a loss as a result of the mid-year shut-down. CO-OP members who had to start over with their deductibles and other out-of-pocket costs in October were the primary examples of people who could file a claim, although there was no guarantee that they would recoup the money they lost.
By the end of 2015, 12 of the original 23 CO-OPs created by the ACA had closed. And although Land of Lincoln Health was not among them, the CO-OP ceased individual and small group enrollments for 2016 mid-way through the open enrollment period, noting that they had already met their enrollment target for the year (Community Health Alliance in Tennessee did the same thing during the 2015 open enrollment period; ultimately they were one of the CO-OPs that shut down at the end of 2015).
Land of Lincoln Health lost $90.8 million in 2015, on the heels of a $17.7 million loss in 2014. And 44 percent of the CO-OP’s 2015 losses occurred in the fourth quarter of the year; losses had been at $50 million as of September 2015. Their losses in 2015 were the highest of all the CO-OPs that were still operational as of the start of 2016.
In 2014, Land of Lincoln Health struggled with low enrollment, with just 3,461 members at the end of 2014 (only about 4 percent of their target). But that changed dramatically in year two. For 2015, Land of Lincoln Health lowered their premiums by 20 to 30 percent, and in most areas of the state, they offered the lowest-priced silver plans.
As a result, their membership ballooned to 50,000 people by the end of the 2015 open enrollment period. Most of them — about 80 percent — had individual market plans, while the rest had small group plans that averaged about 8 to 10 employees each. By the end of 2015, the CO-OP had about 20 percent of the exchange market in Illinois, and about ten percent of the entire individual market in the state.
During the first six months of 2015, Land of Lincoln Health paid out $26 million more in claims than they collected in premiums. In October 2015, HHS announced that carriers across the country – including CO-OPs – would get only 12.6 percent of what they were owed under the risk corridors program. Land of Lincoln sued the federal government in June 2016 over the still-unpaid risk corridor money, but the case was thrown out by a federal judge in November 2016, after Land of Lincoln Health had already closed down.
Land of Lincoln lost $7.1 million in the first quarter of 2016, up from the $5.3 million they lost in the first quarter of 2015.
In June 2016, the risk adjustment payment amounts for 2015 were published, and Land of Lincoln owed $31.8 million—the second-highest amount of any of the remaining CO-OPs. But the Illinois Department of Insurance acted immediately in an effort to block the CO-OP from having to make that payment to HHS. The Department of Insurance’s position was that Land of Lincoln should withhold payment for the 2015 risk corridors program until they receive the $73 million they’re owed for the 2014 risk corridors program.
The letter to CMS regarding blocking the CO-OP from paying the risk adjustment bill was “designed to prevent an immediate liquidation” of Land of Lincoln. Ultimately, that strategy failed, the state of Illinois had no choice but to shut down the CO-OP.
BCBS of Illinois left SHOP exchange, Health Alliance still offering SHOP plans
BCBS of Illinois has announced that they would exit the small business (SHOP) exchange at the end of 2017, but would continue to offer exchange plans for individuals; Illinois had a total of 738 small businesses enrolled in SHOP plans as of early 2017, covering 3,512 members.
Health Alliance is continuing to offer SHOP plans for small businesses, and is the only insurer doing so in Illinois in 2019. Their plans are not available in all areas, however. You can check your zipcode on their site to see if they offer small group plans in your area.
Most small businesses enroll directly with insurers rather than SHOP, and they can still enroll directly with BCBS of Illinois in 2018.
History of the Illinois exchange
Former Gov. Pat Quinn’s administration announced in July 2012 that the Illinois marketplace would operate as a state-federal partnership. Quinn had hoped to leverage the partnership model as an interim step toward a state-run marketplace for the 2015 coverage year. However, a state exchange bill passed in the Senate in 2013 didn’t get a vote in the House. There was some hope that exchange legislation would be considered during the fall 2014 session. However, the House did not take up the issue, and Illinois continues to have a partnership exchange (as noted above, the state’s portion of the partnership was folded into the Department of Insurance in August 2015).
Rep. Robyn Gabel had hoped the issue would gain traction in 2015, given that the U.S. Supreme Court was considering whether premium subsidies could be lawfully provided in states that don’t run their own health insurance exchange. By transitioning to a state-run exchange, Illinois would have secured ongoing subsidies for its residents regardless of how the Court ruled. But the Court ultimately deemed subsidies to be legal in every state, regardless of whether the federal government is running the exchange or not.
About 12 percent of state’s population remained uninsured after the first open enrollment period. In response, officials awarded nearly $26 million to 37 organizations to target groups that were hard to reach in 2014: Latinos, African Americans, and Millennials. The efforts paid off, and Illinois’ uninsured rate dropped again from 2014 to 2015.
Illinois health insurance exchange resources
Get Covered Illinois
Illinois Health Matters
Information resource on health care reform
Health Care Assistance
Office of the Attorney General
877-305-5145 (toll-free nationwide) TTY: 312-964-3013
Serves residents enrolled in private health insurance
Office Consumer Health Insurance and the Ombudsman for the Uninsured
Illinois Department of Insurance
877-527-9431 (toll-free nationwide)
Serves residents who are uninsured as well as residents who have health insurance problems or questions.
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.