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Missouri health insurance exchange / marketplace

Bill would give state state rate review authority - but no denial right

2017 rates

The rates that have been filed for Missouri’s individual market for 2017 are available on Healthcare.gov’s rate review tool. At ACA Signups, Charles Gaba crunched the numbers and came up with a weighted average rate increase of almost 16 percent for the state’s individual market, although he notes that some data is missing and some of it may be flawed.

In particular, Coventry—including both Coventry Health & Life as well as Coventry Health & Life Insurance Company—seems to have a much higher that expected number of enrollees. I talked with the Missouri Department of Insurance about this, and they said that the size of the individual market has “exploded” in Missouri, and that Coventry has picked up a disproportionate number of the new enrollees, since their rates have been among the lowest in the state.

But the DOI also noted that as far as the state’s licensing of health insurance carriers is concerned, they only recognize one Coventry entity—Coventry Health & Life Insurance Company—but that includes an affiliate company, Coventry Health Care of Missouri, which is an HMO (that affiliate entity only shows up on Healthcare.gov’s rate review tool with small group rates). It’s possible that there’s some duplication of membership in the rate filings, although the DOI doesn’t currently have access to the rate filings beyond what’s on Healthcare.gov’s rate review site.

That may change for 2018, however…

Transparency and rate review

In early May 2016, lawmakers in Missouri unanimously passed SB 865, although the governor had not yet signed it as late June. The legislation calls for numerous changes in the state’s health care systems, including added transparency for health insurance rates.

Missouri is currently one of five states that does not have an effective rate review process for ACA-compliant plans. State regulators do not take an active role in reviewing proposed rates, and the Missouri Department of Insurance does not currently have access to the rate filings at all. The federal government (specifically, CCIIO – the Center for Consumer Information and Insurance Oversight) conducts the rate review process forMissouri, and rates are published on Healthcare.gov’s rate review page.

SB 865 gives state regulators a bit more leeway but does not actually give them the power to deny rate changes that aren’t justified. If SB 865 is signed into law, regulators will be able to review and publish rate proposals, and determine whether the proposed rates are reasonable. If they aren’t, the regulators will let the health insurers know, but the insurers will still have the option to implement the rates as-proposed. In that case, the state will be able to publicize the fact that the unjustified rates were implemented, but the state will not have the authority to prevent carriers from implementing rates that aren’t justified.

It should be noted that this system is what CCIIO currently provides in Missouri. The federal government can determine whether proposed rates in the state are justified, but they cannot prevent insurers from implementing unjustified rates. Assuming SB 865 is signed into law, the state would simply take over the process that is currently conducted by CCIIO. According to the Missouri Department of Insurance, this would happen for 2018 rates at the earliest (ie, the rates that will be reviewed in the spring/summer of 2017).

Navigator restrictions permanently blocked by federal judge

Missouri is one of about 15 states that has more restrictive training and certification requirements for navigators than what’s required under federal standards. Missouri legislation also prohibits navigators from providing “advice concerning the benefits, terms and features of a particular health plan, or offer advice about which exchange health plan is better or worse for a particular individual or employer.”

Several health care advocacy groups challenged the restriction on providing advice, saying that is the core function of navigators. In January 2014, a federal judge agreed and issued an injunction to halt enforcement of the law. And in April 2015, a federal appeals court concurred, ruling that Missouri could not restrict navigators from helping people enroll in plans through Heathcare.gov.

In March 2016, a federal judge permanently blocked three sections of Missouri’s restrictions on navigators. Navigators in Missouri cannot be barred from providing advice to enrollees (note that this is limited to explaining the differences between plans – it’s still the case in every state that only a licensed health insurance producer can provide actual plan selection advice). Nor can they be banned from discussing off-exchange plans with consumers. And finally, navigators cannot be required to refer currently-insured consumers to seek advice from a licensed insurance producer. The judge noted that navigators are supposed to be impartial, and forcing them to refer people to insurance agents – who are permitted to recommend one plan over another – would remove some of the impartiality that applies to navigators.

2016 enrollment

290,201 Missouri residents enrolled in private plans through the exchange during the 2016 open enrollment period. Plans that had been cancelled – including plans whose initial payments weren’t made by the due date – by February 1 were already accounted for in the enrollment total. 40 percent of the enrollees were new to the exchange for 2016. The rest already had coverage through the exchange in 2015, and either renewed it or switched to a different exchange plan for 2016.

For perspective, enrollments in the Missouri exchange during the 2015 open enrollment reached 253,430 people, but that was cumulative enrollment with no attrition included. By March 31, 2015, effectuated (in-force) enrollment stood at 219,953. Enrollment in 2016 was 14.5 percent higher than the 2015 number, and already accounted for early attrition.

As of January 21, 44 percent of Missouri residents eligible to enroll in plans through the exchange had done so. That was higher than the national average of 41 percent at that point.

Open enrollment for 2016 coverage ended on January 31. The next open enrollment – for coverage effective in 2017 – will begin on November 1, 2016. Between now and then, enrollment will only be possible for people who experience a qualifying event (Native Americans can enroll year-round, as can anyone who’s eligible for Medicaid or CHIP).

The penalty for being uninsured in 2016 will be much higher than it was in 2014 and 2015: $695 per uninsured adult, or 2.5 percent of household income above the tax filing threshold, whichever is higher.

“Gatekeeper” legislation

Early in the 2016 legislative session in Missouri, legislation was introduced that would allow more broad use of “gatekeepers” in managed care plans. A gatekeeper requirement means that a health plan can require members to see a primary care physician for a referral in order to see a specialist. Current law in Missouri only allows HMOs to utilize a gatekeeper.

Rep. Don Gosen (R, Ballwin), who is the sponsor of one of the bills, has said that his intention is only that EPOs (exclusive provider organizations) would be able to add gatekeepers. But critics of the bills contend that the language is too broad, and that gatekeeper requirements could ultimately be added even to PPO plans, or to a patient’s ability to use out-of-network benefits. As of April, HB2061 was still in committee.

2016 rates and carriers

87 percent of the people who enrolled in private plans through the Missouri exchange for 2016 are receiving premium subsidies. The average pre-subsidy premium in Missouri’s exchange is $407 per month, but for people who are receiving subsidies, the average after-subsidy premium is just $94/month. The average after-subsidy premium across all 38 states that use Healthcare.gov is $106/month.

For perspective, the average pre-subsidy premium in the Missouri exchange in 2015 was $370/month, and it dropped to $86/month once subsidies were applied. 88 percent of enrollees were receiving subsidies in 2015.

According to a Kaiser Family Foundation analysis, enrollees in Missouri’s exchange have more options from which to choose in 2016. In 2015, there were plans available from an average of 2.4 insurers in each county in the state. For 2016, that has increased to an average of 3.1 insurers per county. The total number of participating insurers is unchanged, but some carriers have expanded their service area. Nationwide, the trend is the opposite, with the average number of participating insurers in each county declining slightly from 2015 to 2016.

Benchmark premiums (second-lowest-cost silver plan) increased by an average of 10.4 percent in Missouri in 2016. Subsidies are based on the cost of the benchmark plan in each area, so higher benchmark premiums mean that subsidies are also higher. But it’s important for enrollees to shop around during open enrollment, as subsidy increases don’t apply evenly throughout the state, and aren’t enough to offset all of the premium increases for 2016.

According to Healthcare.gov’s rate review tool, final rate changes for Missouri exchange plans are:

  • All Savers (UnitedHealthcare): 9.9 percent average increase
  • Blue Cross Blue Shield of Kansas City: average rate increases range from 8 percent to 12 percent
  • Cigna: decrease of 2.01 percent.
  • Coventry: average rate increases range from 20 percent to 30 percent (modified somewhat by the federal government during the rate review process)
  • Healthy Alliance Life: 9.77 percent (MSP) and 9.98 percent
  • Humana: 14.81 percent (PPOx)

According to Milliman data, the total number of participating carriers – six – is unchanged from 2015 (although it’s an increase from 2014, when there were only four participating insurers).

2015 enrollment

More than 253,000 Missouri residents enrolled in private health insurance through HealthCare.gov during 2015 open enrollment. About 52 percent of enrollees were first-time shoppers on the marketplace. In 2014, about 152,000 Missourians purchased insurance through the exchange.

In July 2015, HHS released county-level enrollment data for all 37 states that used Healthcare.gov in 2015. Missouri’s enrollment totals for each county can be seen by hovering over the counties on the interactive map.

Some enrollees didn’t pay their initial premiums, and others cancelled their coverage or it was eliminated due to lack of documentation on immigration status. By the end of June, 212,256 people in Missouri had effectuated private-plan coverage through the exchange. 89 percent of them were receiving premiums subsidies, which averaged $278 per month and reduced average premium payments from $363 to $85 per month.

Subsidies safe in Missouri

The continued availability of subsidies in Missouri was uncertain for the first half of 2015, because the state uses the federally-run exchange. The King v. Burwell lawsuit challenged the legality of subsidies in the federally-run exchange, with plaintiffs claiming that subsidies could only be provided by state-run exchanges. But on June 25, the Supreme Court ruled that subsidies are legal in every state, which means that 189,000 people in Missouri were no longer in danger of losing their premium subsidies, and their premiums did not increase by 327 percent – which would have been the case if subsidies had been eliminated.

Even people who weren’t receiving subsidies would have been priced out of the insurance market if subsidies had been eliminated. If subsidies had been eliminated, The Urban Institute had projected a 55 percent spike in premiums (in addition to regular annual rate increases) for people who were paying full price for their coverage. They also predicted that the overall individual market risk pool size would have dropped by 70 percent if the Supreme Court had struck down the subsidies. Fortunately for the residents, medical providers, and insurers in Missouri, that didn’t happen.

SHOP exchange

Missouri small businesses (those with 50 or fewer employees) can shop for health insurance through HealthCare.gov year-round.

Starting with the 2015 coverage year, Missouri’s small employers were able to offer their employees a choice of several health plans within a single metal level through the SHOP’s “employee choice” option. Missouri was among 14 states using the federal exchange to implement employee choice starting in 2015.

How many people enrolled in 2014?

More than 152,000 Missourians purchased health insurance through the marketplace during 2014 open enrollment. That’s 23.2 percent of the estimated eligible market according to the Kaiser Family Foundation. The national average was 28 percent.

In addition to those purchasing private insurance plans, 45,513 people qualified for either Medicaid or the Children’s Health Insurance Program (CHIP).

Among Missouri residents who purchased health insurance, 85 percent qualified for financial assistance, which matches the national figure. A report released in June by HHS showed the average monthly premium, after tax credits, for Missouri consumers was $59. Fifty-seven percent of enrollees paid $50 or less per month after subsidies.

Twenty-one percent of Missouri residents selected a bronze plan (20 percent nationally), 63 percent selected a silver plan (65 percent nationally), 13 percent selected a gold plan (9 percent nationally), 0 percent selected a platinum plan (5 percent nationally) and 3 percent selected a catastrophic plan (2 percent nationally). Twenty-nine percent of Missouri enrollees were between the ages of 18 and 34.

Missouri exchange history

Many Missouri legislators have steadfastly fought against the Affordable Care Act and implementation of the health insurance marketplace.

Legislation to establish an exchange was introduced but failed to pass in both 2011 and 2012. Despite the lack of legislative authorization, some initial workgroups were established. In 2011, Gov. Jay Nixon established the Health Insurance Exchange Coordinating Council, which did some initial scoping and planning. Also in 2011, the Senate created the Interim Committee on Health Insurance Exchanges to explore Missouri’s options to establish a state-based exchange.

Members of the Interim Senate committee refused to authorize the use of federal grant money. In April 2012, the Missouri legislature rejected a $50 million grant to upgrade the state’s Medicaid information system as some legislators believed the system would be used as a springboard to building a state-run exchange.

In May 2012, the Missouri legislature approved a ballot measure to prevent the executive branch from authorizing a state-based health insurance exchange without legislative or popular approval — even though Gov. Nixon repeatedly stated his administration would not authorize an exchange by executive order. Voters passed the ballot measure in November 2012, and state defaulted to the federally operated exchange.

In January 2015, Republican Sen. Bob Onder filed a bill that he said was aimed at blocking the Affordable Care Act’s individual mandate. SB 51 would have revoked a health insurance company’s license to sell policies in Missouri if it accepts federal subsidies for policies sold through the federal marketplace. It’s questionable what impact the bill would have had if it had passed. One legal expert told the St. Louis Post-Dispatch, “It’s sort of an exercise in futility.” Ultimately, the bill didn’t advance out of committee.

Missouri health insurance exchange links

HealthCare.gov
800-318-2596

State Exchange Profile: Missouri
The Henry J. Kaiser Family Foundation overview of Missouri’s progress toward creating a state health insurance exchange.

Missouri Department of Insurance
Assists people insured by private health plans, Medicaid, or other plans in resolving problems pertaining to their health coverage; assists uninsured residents with access to care.
(800) 726-7390 / consumeraffairs@insurance.mo.gov

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