Wisconsin uses the federally-run exchange, which means residents use HealthCare.gov to enroll in exchange plans. Wisconsin has a very robust health insurance exchange, with 14 carriers offering plans in 2017 — far more than most other states. And almost two-thirds of Wisconsin’s individual market enrollees have coverage through the exchange (as opposed to off-exchange).
But the future of health care reform is uncertain. The GOP’s American Health Care Act (AHCA) could result in hundreds of thousands of people in Wisconsin becoming uninsured over the next decade, and the CBO has projected that the legislation would lead to average premium increases of 15 to 20 percent for 2018 coverage (more details below). The Senate’s version of the bill, the Better Care Reconciliation Act (BCRA) makes some changes to the House bill, but is also expected to result in higher premiums in 2018 (due to the retroactive elimination of the individual mandate penalty) and far more uninsured Americans over the coming decade.
Two Democratic state lawmakers in Wisconsin are planning to introduce a bill that would allow state residents to buy into BadgerCare, the state’s Medicaid program. This would serve as a public option, competing with private insurance plans in the individual market. Citizen Action of Wisconsin, an advocacy group, supports the push for a public option in Wisconsin, although the legislation will likely face an uphill battle in the Republican-controlled Wisconsin legislature. New Mexico lawmakers recently passed a similar bill, but Governor Brian Sandoval vetoed it. For now, there are no states where residents who aren’t eligible for Medicaid can buy into the program.
Enrollment higher in 2017
242,863 people enrolled in coverage for 2017 through the Wisconsin exchange during open enrollment, including new enrollees and renewals. For perspective, 239,034 people enrolled in coverage through the Wisconsin exchange during the 2016 open enrollment period. Nationwide, there was an average decline in enrollments across states that use HealthCare.gov, but Wisconsin bucked that trend and saw a small increase in enrollment.
Looking ahead to 2018: Anthem exiting, but their market share is very small
Open enrollment for 2018 coverage will begin on November 1, 2017, and end of December 15, 2017. All plans selected during open enrollment will take effect January 1, 2018.
Insurers that wish to offer individual market health plans in Wisconsin in 2018 must submit proposed rates and plans via SERFF or to the Wisconsin Office of the Insurance Commissioner by July 14, 2017. Wisconsin has one of the most robust exchanges in the country in terms of the number of participating insurers, but Anthem will be leaving the exchange at the end of 2017, and will only offer one off-exchange plan in one county (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 is likely to be extremely low in 2018). The continuation of off-exchange coverage in Menominee County prevents a full market exit, which means that Anthem will have 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 pre-date the ACA.
Anthem offers individual market plans in the exchange in 34 of Wisconsin’s 72 counties, but unlike their strong market presence in most states, they only have about 5 percent of the individual market share in Wisconsin. Anthem exited Milwaukee, Racine and Kenosha counties — all populous areas — at the end of 2015, and scaled back their exchange offerings in the 34 counties where they’ve continued to offer coverage. They have 18,500 members in the individual market, about three-quarters of whom will need to select new coverage during open enrollment (the rest have grandmothered and grandfathered plans that are not being terminated by Anthem).
The individual health insurance market is experiencing considerable instability, largely due to the Trump Administration’s lack of clarity in terms of ongoing funding for cost-sharing reductions (CSR). Under the ACA, health plans must provide more robust coverage (ie, enhanced with CSR) to eligible low-income enrollees. The federal government is supposed to reimburse health plans for the cost of doing so, and thus far, the reimbursements have been funded.
But House Republicans sued the Obama Administration in 2014, alleging that CSR funding was never appropriated by Congress. A court sided with House Republicans in 2016, but the Obama Administration appealed and the money continued to flow to insurers. Since the Trump Administration took office, the lawsuit has been pended. The most recent extension of the stay in the case was on May 22, and it pushes the case out another three months, until late August — after pricing has to be proposed for 2018 coverage. The BCRA appropriates funding for cost-sharing reductions through the end of 2019, but would eliminate them after that. This would provide some stability in the insurance markets for the immediate future, but would make health care unaffordable for low-income people after 2019, since cost-sharing reductions are the mechanism by which they currently get lower health insurance premiums.
Wisconsin and the AHCA, BCRA
According to an HHS report published in December 2016, the ACA resulted in a gain of 211,000 people with health insurance in Wisconsin from 2010 to 2015, and coverage gains continued in 2016. Under the AHCA, those coverage gains would be erased. The CBO projects that the legislation would result in 23 million additional uninsured people in the U.S. by 2026. Some of these people would voluntarily drop coverage with the elimination of the ACA’s individual mandate penalty, while others would find coverage unaffordable. Some would lose access to Medicaid under the AHCA (particularly in 2020 and beyond), and others would lose access to employer-sponsored insurance with the elimination of the employer mandate penalty.
The AHCA would change the way premium tax credits are provided. As of 2020, tax credits would vary only by age, and would be available in full to individuals earning up to $75,000 and couples earning up to $150,000 (they would phase out above that level). But unlike the current ACA tax credits (subsidies), they would not be larger for lower-income enrollees, and they would not vary based on the cost of health insurance in a given area.
In Wisconsin, that means people in the rural northwestern part of the state (which voted heavily for Trump) would be subject to the biggest losses under the AHAC. A 60-year-old earning $30,000/year in northwestern Wisconsin would lose more than $6,000/year in tax credits if the AHCA were to be enacted.
The Senate wrote their own bill, and they can only afford to lose votes from two Republican Senators if their measure is to pass. The Senate’s version, the BCRA, keeps the ACA’s subsidy structure much more intact, but increases the percentage of income that older people would have to pay for their coverage (rather than making it based only on income, the way the ACA works), and just like the AHCA, the BCRA allows insurers to charge older enrollees five times as much as younger enrollees.
For the time being, nothing has changed. ACA subsidies are still available in the exchange, and health plans are still guaranteed-issue, regardless of medical history. Open enrollment for 2017 coverage ceased at the end of January, but you can still enroll if you have a qualifying event. Native Americans can enroll year-round, as can anyone eligible for Medicaid or CHIP.
Wisconsin Insurance Commissioner supports AHCA & return to high-risk pools
The day after House Republicans passed the AHCA, Wisconsin Insurance Commissioner, Ted Nickel, voiced his support to the legislation. In a May 19 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 Scott 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 allow states to opt out of the ACA’s essential health benefits requirements; they would also be 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.
2017 rates and carriers: 15.9% rate hike, largely mitigated by subsidies
14 carriers are offering 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 have joined the exchange for 2017.
You can click on your county on this map to see which carriers are offering individual market plans, and whether they’re available in the exchange.
Carriers filed proposed rates for 2017, which were reviewed by state regulators during the summer. The final approved average rate changes amount to an average rate increase of 15.9 percent for plans sold through the exchange. The following average rate changes were approved for 2017:
- Anthem Blue Cross Blue Shield (CompCare Health Services) = 21.94 percent
- Aspirus Arise = new to Wisconsin for 2017 in 16 north-central counties (Aspirus Arise is a separate entity from Arise Health Plan)
- Common Ground Healthcare Cooperative = 27.7 percent (19,300 members in 2016; this rate increase was the approval of a second filing that Common Ground submitted in September, and was considerably higher than their initial proposed average rate increase of 12.6 percent)
- Children’s Community Health Plan = CCHP is new to the exchange for 2017. They are offering exchange plans in six southeastern Wisconsin counties in 2017: Kenosha, Milwaukee, Ozaukee, Racine, Washington, and Waukesha.
- Dean Health Plan = 18.7 percent (28,900 members in 2016)
- Group Health Cooperative of South Central Wisconsin = 5.44 percent
- Gunderson Health Plan Inc. = 18.3 percent (GundersonOne’s average was 17.5 percent; GundersonOneHSA’s average was 18.8 percent)
- Health Tradition Health Plan = 24.32 percent (9,577 members in 2016)
- Medica Health Plans of Wisconsin = 11.2 percent (9,313 members in 2016)
- MercyCare HMO Inc. = average rate decrease of 13 percent
- Molina = 27 percent (63,530 members plans are not being marketed outside the exchange)
- Network Health = 23.65 percent
- Security Health Plan of Wisconsin, Inc. = 13.8 percent for Classic; 17.2 percent for Select
- Unity Health Insurance = Depending on plan, average approved rate increases were 27.2 percent, 28.7 percent, and 37.9 percent.
Although the average rate increase in the exchange was nearly 16 percent, that figure doesn’t include subsidies. 85 percent of Wisconsin exchange enrollees were receiving subsidies as of March 2016. For those folks, as long as they were willing to shop around during open enrollment and be flexible about the possibility of having to switch plans, the 2017 subsidies will largely mitigate the rate hikes. The subsidies are based on the cost of the benchmark plan (second-lowest-cost silver plan), and HHS reported that the average benchmark premium in Wisconsin is 16 percent higher in 2017; subsidies increase to keep up with the benchmark rates.
For perspective, the average rate changes that each of these carriers implemented in 2016 are listed further down this page.
State objected to HHS re-enrollment plan
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 Scott 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 note that as far as they’re concerned, the proposal to automatically re-enroll people in plans from different carriers essentially amounts to selling health insurance without a license, which is not permitted in Wisconsin (or any other state, for that matter).
In early October, 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 have been vocal in letting their residents know about the opt-out feature)
On October 31, the day before open enrollment began, Nickel published a bulletin for insurers in Wisconsin, reiterating the fact that the state considers 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.
Humana, Ambetter, and United exited individual market; Arise and Physicians Plus left exchange
People whose coverage was terminating at the end of December had an opportunity to select coverage from another carrier – on or off-exchange – in November or December in order to maintain continuous coverage. Open enrollment continues until January 31, but those members also have the month of February to pick a new plan if they haven’t already done so, as loss of coverage is a qualifying event that triggers a special enrollment period.
Humana left the individual market in Wisconsin at the end of 2016, as was the case in at least a handful of other states. Humana did not participate in the exchange in Wisconsin, so their exit only impacted off-exchange plans. According to Humana’s letter regarding their exit, there were 6,639 members whose coverage was scheduled to terminate at the end of 2016.
UnitedHealthcare also exited the individual market in Wisconsin at the end of 2016. United offered plans in 56 of Wisconsin’s 72 counties in 2016, but they had one of the two lowest-cost silver plans in just one of those counties.
Ambetter (Managed Health Services Insurance Corp.) confirmed by phone in September that they would not offer any individual market plans in Wisconsin in 2017.
In late September, WPS (Arise) announced that they would not offer plans in the exchange in 2017, but would continue to offer plans outside the exchange. According to their rate filing, They are only offering off-exchange plans in 19.5 counties (out of the 39 counties where they offered coverage in 2016), and are limiting their off-exchange plans to Bronze and Catastrophic plans in 2017. Arise had a “small share” of the individual market in 2016. As noted above, Aspirus Arise (a new, separate entity) began offering coverage in north-central Wisconsin in 2017, on and off the exchange.
In their rate filing memo, Physicians Plus confirmed that their plans would only be offered outside the exchange in Wisconsin in 2017, and that they would exit the exchange at the end of 2016.
Children’s Community Health Plan and Aspirus Arise joined exchange
Children’s Community Health Plan (CCHP) is an HMO owned by Children’s Hospital of Wisconsin, and prior to 2017, they only offered coverage through Wisconsin’s BadgerCare Medicaid program. In the fall of 2015, CCHP expressed interest in offering plans on the Wisconsin exchange in 2017, and began working through the filing process involved.
By February 2016, their request had been filed with the Office of the Commissioner of Insurance, and was under review. But the Wisconsin Office of the Commissioner of Insurance confirmed by phone in May that CCHP’s application to offer QHPs in the marketplace was being processed by the federal government, not the state.
The proposal was approved, and the Milwaukee Journal Sentinel confirmed in July 2016 that CCHP would offer plans in the Wisconsin exchange when open enrollment begins in November. By early October, CCHP had been added to the Wisconsin Office of the Insurance Commissioner’s list of approved individual market carriers. They are offering exchange plans in six southeastern Wisconsin counties in 2017: Kenosha, Milwaukee, Ozaukee, Racine, Washington, and Waukesha.
CCHP is clearly planning to start small, as Bob Duncan, executive vice president of CCHP’s community services, has said that he’ll “be excited if [they] have 1,000 or 2,000 new members in the first year.”
Aspirus Arise is a new carrier, offering HMO and POS plans in 16 north-central Wisconsin counties in 2017, both on and off the exchange. Aspirus Arise confirmed by phone that they are a separate entity from Arise Health Plan. The carrier was created in a joint effort in 2016 by Aspirus and Arise.
CO-OP still open after capital infusion in 2016
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 five are still operational heading into 2017; Common Ground is one of them.
By early 2017, Common Ground reported that they had experienced strong enrollment growth during in November and December, and had roughly 32,000 enrollees by that point. They had roughly 19,000 members in 2016, and their target for 2017 had been 30,000 to 35,000 enrollees.
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 percent 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. In November 2015, Common Ground announced that they were adding Bellin Health System to their Envision Integrated Care Network, which also includes Aurora Health Care. In 2015, there were 23,629 members enrolled in Common Ground Healthcare CO-OP plans.
Of the 11 CO-OPs that were still operational at the start of 2016, six had announced their closures by late 2016. Common Ground is among the five that are still 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.
Milwaukee wins 2016 White House enrollment challenge
Early in the 2016 open enrollment period, the White House reached out to leaders in 20 metropolitan areas across the country, challenging them to promote outreach to enroll as many residents as possible during open enrollment. HHS and state-based marketplaces looked at total new enrollment in each area, and compared those numbers with the estimated number of uninsured residents in each area prior to open enrollment.
In February 2016, the White House announced that Milwaukee had won the challenge, with 38,000 newly-enrolled residents during the 2016 open enrollment period. President Obama will visit the city to “celebrate their success in helping ensure Americans have health coverage.”
239k enrolled for 2016
239,034 people enrolled in private plans through the Wisconsin exchange during the 2016 open enrollment period, including new enrollees and renewals. There were 183,682 people with in-force coverage through the exchange in mid-2015, and most of them were likely among the renewals for 2016.
For perspective, 207,349 people enrolled in plans through the Wisconsin exchange during the 2015 open enrollment period, so the 2016 enrollment total is 15 percent higher than the prior year.
Effectuated enrollment as of March 31 stood at 224,208. Of those enrollees, 85 percent are receiving subsidies that average $332 per month.
Open enrollment for 2016 ended on January 31. But people who experience a qualifying event can still enroll in a plan for 2016, as can anyone eligible for Medicaid or CHIP. Native Americans can also enroll in coverage through the exchange year-round.
The penalty for being uninsured is significantly higher in 2016 than it was in 2014 and 2015. Given the sharp increase in the penalty, many residents – particularly those who qualify for premium subsidies – have found that they can fund several months worth of health insurance premiums with the money that would otherwise have been owed as a penalty had they remaining uninsured.
Network Health joins exchange for 2016
Network Health joined the Wisconsin exchange for 2016, offering plans in seven counties: Calumet, Milwaukee, Outagamie, Ozaukee, Racine, Waukesha, and Winnebago. The plans are also available outside the exchange.
Anthem exits exchange for 2016 in some counties
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. In 2012, those three counties had a total population of more than 1.3 million people, out of 5.7 million people state-wide. Anthem also announced that they would significantly reduce the number of available plans in 34 other counties in the state.
Anthem enrollees whose plans terminated were able to select a new plan from one of the other carriers for 2016.
2016 carriers and their rate changes
16 carriers offered individual plans through the Wisconsin health insurance exchange in 2016, although not all carriers offered plans in all areas of the state (the Wisconsin Office of the Commissioner of Insurance has a webpage that shows which plans are available in each county, including off-exchange plans). Wisconsin exchange carriers – and their average rate changes for 2016, if available – are listed below:
- All Savers Insurance Company (UnitedHealthcare) = 20.1% rate increase (15,102 members in 2015)
- Ambetter (Managed Health Services Insurance Corp.) = 9.2% rate decrease
- Anthem Blue Cross Blue Shield (CompCare Health Services) = 9.5% and 9.8% rate increases, depending on plan
- Common Ground Healthcare Cooperative = 18% rate increase (23,629 members in 2015)
- Dean Health Plan = 10.2% decrease for EPO; 3.9% decrease for HMO; 9.7% increase for Prevea360 HMO
- Group Health Cooperative of South Central Wisconsin = 10.9% rate increase (853 members in 2015)
- Gunderson Health Plan Inc. = 8.1% and 8.8% rate increases, depending on plan
- Health Tradition Health Plan = 0.6% rate increase
- Medica Health Plans of Wisconsin = 9.6% rate increase
- MercyCare HMO Inc. = 8.1% rate decrease
- Molina = 1.4% rate increase
- Network Health = new for 2016
- Physicians Plus = 5.1% rate decrease
- Security Health Plan of Wisconsin, Inc. = 13.5% rate increase for Select Plans; 22.7% increase for Classic Plans (20,819 members on Classic plans in 2015)
- Unity Health Insurance = rate increases ranging from 1.7% to 11%
- WPS Health Plan Inc. (Arise) = rate increases ranging from 17.3% to 20.8%
Ambetter (Managed Health Services Ins. Corp.) and All Savers (UnitedHealthcare) were new to the Wisconsin exchange in 2015, and Network Health was new to the exchange in 2016. All Savers will exit the Wisconsin market at the end of 2016, but CCHP will begin offering exchange plans in 2017.
Medica is continuing to offer health plans in the individual exchange in Wisconsin, but has exited the SHOP exchange that provides coverage for small businesses. Medica also exited the SHOP exchanges in Minnesota and North Dakota, and noted that the issue was simply a lack of interest from small businesses and brokers.
A week before the start of open enrollment, Healthcare.gov debuted 2016 rates and plans so consumers could begin browsing the available plans. Within the exchange, four carriers had lower average rates for 2016 than they had in 2015. Health Network was new for 2016, and the other 11 carriers had average rate increases that range from less than one percent to almost 21 percent.
According to Citizen Action of Wisconsin, the average premium in Madison was the same in 2016 as it was in 2015. For a 40-year-old who purchased the second-lowest-cost Silver plan (benchmark plan), the premium was $254/month both years (this doesn’t take into account any subsidies). Statewide, however, the average benchmark premium across 19 metropolitan areas in 2016 was $319, which is 4.2 percent higher than it was in 2015 (note that the benchmark plan can be a different plan and carrier from one year to the next – it’s just the second-lowest-cost Silver plan for a given year). Across the entire state, the average benchmark premium is 4.7 percent higher than it was in 2015. For enrollees who are receiving subsidies, the subsidies will be slightly larger in most cases in 2016 to reflect the increased benchmark plan costs.
The average benchmark plan deductible in Madison is lower in 2016 than it was in 2015: $3,400, down from $4,000. But state-wide, the average deductible is more than $1,000 higher in 2016 than it was in 2015.
Common Ground’s (an ACA-created CO-OP) initial rate proposal didn’t show up on Healthcare.gov’s rate review tool, so we can assume it was less than ten percent. But in October, Common Ground Health Cooperative resubmitted a new rate proposal to the Office of the Insurance Commissioner. According to that document, the approved weighted average rate change for Common Ground is 18 percent (this has since been verified on Healthcare.gov’s rate review tool), and impacted 23,629 enrollees in Wisconsin.
All of the weighted average rate changes assumed that people didn’t shop around and switch plans during open enrollment, which obviously wasn’t the case. Ultimately, due to plan changes, the effective average rate increase ended up being lower than the projected weighted averages. When all plan selections had been made during the 2016 open enrollment period, 84 percent of exchange enrollees in Wisconsin qualified for premium subsidies. Their average pre-subsidy rate is $455/month, while their average after-subsidy premium is $125/month.
For perspective, in 2015, 89 percent of Wisconsin exchange enrollees qualified for subsidies. Their average pre-subsidy premium was $440/month, but their average after-subsidy premium was $125/month – the same as it is in 2016. For people who are receiving subsidies, the subsidies combined with different plan selections during open enrollment have resulted in the same average after-subsidy premium two years in a row.
Bill to increase rate oversight did not pass
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 give the Insurance Commissioner the ability to deny rate hikes that aren’t justified by claims costs. Currently, Wisconsin is a “file and use” state, which means that carriers set their own rates, and must simply file them with the state no more than 30 days after implementation.
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 ten percent or more. 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’s health insurance rates were dramatically higher than neighboring Minnesota in the first few years of ACA implementation. In 2015 the average benchmark (second lowest cost silver) plan in Wisconsin cost $373/month (before any subsidies), which was the fourth highest average in the country. In Minnesota, the average benchmark plan cost just $183/month in 2015.
In 2016, Wisconsin has the seventh highest pre-subsidy rates among the 38 states that use Healthcare.gov. Consumer advocates note that Wisconsin’s lax health insurance rate review process is harmful to consumers, as there is little that state regulators can currently do to hold rates in check.
But for 2017, the average rate increase in Wisconsin (15.9 percent) is lower than the national average (about 25 percent). And in Minnesota’s exchange, every carrier has average rate increases of more than 50 percent.
Gov. Walker and the King case
Since Wisconsin has a federally-run exchange, the Supreme Court’s decision in King v. Burwell was of critical importance in the state. The plaintiffs argued that the ACA only allowed subsidies to be provided in state-run exchanges, and 34 states – including Wisconsin – had federally-run exchanges (Healthcare.gov) instead. But in June 2015, the Court ruled that subsidies are legal in every state, including those that use Healthcare.gov.
In January 2015, ThinkProgress put forth a video from 2013 of Wisconsin Governor Scott Walker saying that there’s “no real substantive difference between a federal exchange or a state exchange…” ACA supporters who wanted the Supreme Court to rule that subsidies are available in every state jumped on Walker’s comments as proof that nobody who was implementing the ACA was aware of the fact that subsidies might be in jeopardy in federally-run exchanges.
Indeed, Walker’s unique solution to Medicaid expansion (details below) indicates that he clearly believed that subsidies would be available in federally-run exchanges, since Wisconsin shifted about 83,000 people from Medicaid to subsidized plans in the exchanges as of 2014 (they are enrollees with incomes between the poverty level and 138 percent of the poverty level, so they are currently eligible for subsidies in the exchange).
But Vox’s Sarah Kliff explained that Walker’s comments didn’t really dismantle the King case, as he was simply talking about who would really be running the show in the exchange, and was pointing out that the state would have to comply with the federal government’s requirements, even if it were technically a state-run exchange.
And to be clear, Walker is no fan of Obamacare. He’s repeatedly called for repeal of the law, and following the Supreme Court’s ruling, Walker said that lawmakers should “redouble their efforts to repeal and replace” the ACA.
2015 enrollment numbers
As of February 22 – after the second open enrollment period had ended – 207,349 people in Wisconsin had finalized their 2015 private plan enrollments through the exchange. Of those enrollees, 90 percent qualified for premium subsidies. More than half of the enrollees (115,755) were renewing plans from 2014, and of those renewals, more than half (66,759) were “active” renewals as opposed to auto-renewals. Of the active renewals, 40,303 switched to a new plan for 2015.
By the end of June, effectuated enrollment in private plans through the Wisconsin exchange stood at 183,682. Attrition is to be expected in the individual health insurance market; some enrollees never pay their initial premiums, while others choose to cancel their plans mid-year. In addition, Healthcare.gov has stepped up enforcement of documentation requirements for immigration and income verification, which has resulted in the termination of some plans and/or premium subsidies.
In addition to the private plan enrollments, another 27,628 exchange enrollees in Wisconsin were eligible for Medicaid or CHIP during the 2015 open enrollment period. Medicaid enrollment continues year-round, but tends to increase during the general open enrollment due to additional outreach and advertising.
Open enrollment for 2015 has ended, and most people can only purchase a new plan at this point (including off-exchange) if they have a qualifying event. However, enrollment is year-round for Native Americans and for enrollees who qualify for Medicaid or CHIP.
Average 2015 rate increase of just 3 percent
In late September, the Wisconsin Office of the Commissioner of Insurance released rate filings for 2015 health plans. The average rate increase in Wisconsin’s individual market (including on and off-exchange plans) is just 3.2 percent for 2015. And two carriers – Medica Health Plans of Wisconsin and Molina Healthcare of Wisconsin – have reduced their premiums by 17 and 11 percent, respectively. Anthem’s rates have increased an average of 9 percent, but that includes exchange plans as well as plans sold outside the exchange.
For a 40 year-old non-smoker, a Commonwealth Fund analysis calculated an average rate increase of 7 percent in the exchange in Wisconsin for 2015, across all metal levels. For people who are enrolled in the benchmark plan (second lowest-cost silver plan) from 2014, The NY Times Upshot found that they could see rate decreases across much of the southern and western portions of Wisconsin, as long as they’re willing to switch to the new benchmark plan for 2015.
There is significant disparity in rate changes from one area of the state to another though. The northeast part of Wisconsin has had the highest rate of health insurance inflation in the state over the last 14 years, although people enrolled in the benchmark plan there should see average rates increases under 6 percent for 2015.
In the Milwaukee area, the benchmark plan is offered by a different carrier in 2015, and so are the lowest-cost silver and bronze plans. People who are on a plan that was auto-renewed on December 15 are still eligible to shop for a new plan anytime until February 15, and Wisconsin is a market where it’s definitely worth shopping around during open enrollment.
New carriers joined the exchange in 2015
The federally-facilitated (ie, through HealthCare.gov) Wisconsin exchange had 13 carriers in 2014, but has 15 for 2015. Two new carriers – UnitedHealthcare and Managed Health Services Insurance Corporation (AmBetter) – joined the exchange for 2015, and their entry is one of the factors that held down rate increases.
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.
In late October 2013, Citizen Action of Wisconsin created a report highlighting 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. 2014 rates in Wisconsin are double the rates of neighboring Minnesota. But the rate increase for 2015 – an average of just three percent – is significantly lower than the 5.4 percent national average rate increase.
Despite the small increase for 2015, Citizen Action of Wisconsin released a new report in October that highlighted the ongoing differences between the neighboring states, and the expectation that rates would still be higher in Wisconsin than in Minnesota in 2015.
How many people enrolled in 2014?
The 2014 Obamacare open enrollment period ended in April. 139,815 people had purchased private plans in the Wisconsin exchange by April 19 – nearly a 96 percent increase over the number who had done so by March 1.
In addition to the private plan Obamacare enrollments, Wisconsin’s exchange has also enrolled 97,509 residents in the state’s BadgerCare Medicaid program by the end of June.
According to a Gallup poll, 11.6 percent of Wisconsin’s population lacked health insurance in 2013. The poll found that the rate had dropped to 9.6 percent by the middle of 2014.
Wisconsin Medicaid – a unique approach…
Wisconsin has not expanded Medicaid under the ACA, but has taken a more proactive approach than most non-expansion states in providing coverage for people living in poverty. Wisconsin dropped the existing BadgerCare Medicaid eligibility to 100% of poverty level, which resulted in 72,000 people losing BadgerCare eligibility. Since subsidies for private Obamacare plans purchased in the exchange begin at 100% of poverty level, the residents who lost BadgerCare eligibility were able to purchase heavily subsidized plans in the exchange instead.
However, critics have noted that a lot of those 72,000 people (with incomes just over 100% of poverty) were probably unable to afford a private plan, even with the available cost-sharing and premium subsidies.
As of the beginning of September, the state estimated that 25,800 former BadgerCare members had not yet enrolled in a subsidized plan through the exchange. They initially had until June 30 to do so, but HHS has granted them another special enrollment period – September 4 through November 2 – during which they could apply for a subsidized plan in the federally-facilitated Wisconsin exchange. The Wisconsin Department of Health Services sent letters to the former BadgerCare enrollees who had not yet obtained new coverage, informing them of the special enrollment period.
But an additional 83,000 childless adults with incomes below 100% of poverty level are newly eligible for BadgerCare in 2014. Wisconsin created their own version of Medicaid reform without using the federal funds allocated by the ACA. As a result, the state was able to make its own rules, and people in Wisconsin with household incomes between 100% and 138% of poverty level are expected to purchase subsidized private plans – they are not eligible for Medicaid.
…but not fully expanded Medicaid
Technically, this means Wisconsin has not expanded Medicaid under the ACA (if it did, people with incomes up to 138 percent of poverty would be eligible for Medicaid and the state would receive federal funding for Medicaid expansion). Although Governor Scott Walker has received criticism from consumer advocates, among states that have not expanded Medicaid, Wisconsin is the only one without a coverage gap, since BadgerCare was expanded to cover everyone up to 100% of poverty level (in most states that did not expand Medicaid, eligibility limits are far lower than that).
Nevertheless, 19 Wisconsin counties and the city of Kenosha added referendum questions to their ballots in November 2014, asking citizens to weigh in on Gov. Walker’s decision to not fully expand Medicaid under the ACA. Voters passed all 20 of the ballot initiatives, but they are essentially just a way of communicating resident wishes to lawmakers, as the final decision on expanding Medicaid is up to the Governor and the state’s lawmakers.
Wisconsin’s go-it-alone approach to modified Medicaid expansion could end up being financially challenging, as the state incurred significantly higher Medicaid spending in 2014 and did not have the federal government funding Medicaid expansion as they would do if the state followed the guidelines laid out in the ACA (federal funding would have covered 100 percent of newly-eligible enrollees through 2016, and then the state would gradually pay a small portion of the new expenses, capping out at 10 percent by 2020).
Over four years, it’s estimated that the total cost to state and federal taxpayers for Wisconsin’s unique approach to Medicaid will be $2 billion more than it would have been under straight Medicaid expansion as called for in the ACA.
Wisconsin exchange history
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 health insurance exchange links
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@example.com
State Exchange Profile: Wisconsin
The Henry J. Kaiser Family Foundation overview of Wisconsin’s progress toward creating a state health insurance exchange.