Latest Wisconsin exchange updates
- Molina rejoining Wisconsin exchange for 2019
- Average premiums in Wisconsin exchange will drop in 2019, thanks to reinsurance
- 2018 enrollment down about 7% from 2017
- State will receive federal funding for reinsurance to stabilize individual market
- All areas — including Menominee County — have plans available in 2018
- 11 insurers offering plans for 2018 exchange coverage
- Rates sharply higher in 2018 due to elimination of CSR funding
- Anthem, Molina, and Health Tradition Health Plans exited at the end of 2017
- Gunderson merged with UW Health/UnityPoint
- Lawmakers considered, but didn’t pass, Medicaid buy-in
Wisconsin exchange overview
Wisconsin uses the federally run exchange, which means residents use HealthCare.gov to enroll in exchange plans. Wisconsin has a generally robust health insurance exchange, with 11 carriers offering plans in 2018 — far more than most other states. But coverage is localized, and most counties in the northern half of the state have only one or two insurers offering plans for 2018.
Almost two-thirds of Wisconsin’s individual market enrollees have coverage through the exchange (as opposed to off-exchange).
There were 14 insurers offering plans in the Wisconsin exchange in 2017, but three left at the end of 2017. Rates are sharply higher in 2018, but a significant portion of the rate increase was due to the elimination of federal funding for cost-sharing reductions (CSR). The cost of CSR has been added to silver plans, which means premium subsidies are also significantly larger for 2018.
Looking ahead to 2019: Molina rejoining exchange; average premiums dropping by 3.5% thanks to reinsurance.
Rate filings for 2019 plans that will be sold in Wisconsin’s exchange had to be submitted to the Wisconsin Office of the Commissioner of Insurance by July 2, 2018. Insurers in Wisconsin submitted two sets of rates for 2019 — one based on the state’s proposed reinsurance program being approved by CMS and implemented, and the other based on not having a reinsurance program in place. The waiver proposal was approved by CMS in late July, and weighted average rates are expected to decrease by an average of 3.5 percent as a result (see details below about the state’s reinsurance program).
The average proposed rate increases for Wisconsin’s exchange insurers are:
- Aspirus Arise: 12.88 percent increase (Aspirus Arise HMO); 13.66 percent increase (Aspirus Arise POS).
- Common Ground Healthcare Cooperative: 18.94 percent DECREASE
- Children’s Community Health Plan: 8.84 percent increase
- Dean Health Plan:6.11 percent DECREASE
- Group Health Cooperative of South Central Wisconsin: 0.17 percent increase or 4.51 percent increase, depending on the product
- HealthPartners Insurance: 20.58 percent: No rate change (and a slight decrease for off-exchange plans)
- Medica Health Plans of Wisconsin: 1.39 percent increase
- MercyCare HMO Inc: 9.21 percent
- Molina: 18.4 percent DECREASE. Molina is rejoining the Wisconsin exchange for 2019, after exiting at the end of 2017. Plans will not be marketed off-exchange in 2019. They offered an off-exchange bronze plan in 2018, but will discontinue it for 2019. They will only offer on-exchange silver and gold plans. Molina has no membership in Wisconsin in 2018, but is projecting nearly 25,000 members in 2019.
- Network Health: 7.56 percent DECREASE or 3.53 percent DECREASE, depending on the region.
- Security Health Plan of Wisconsin, Inc: 10.17 percent increase (Select); 11.95 percent increase (Protect)
- Unity Health Insurance: 8.8 percent DECREASE.
225,435 people enrolled in private plans through Wisconsin’s exchange during the open enrollment period for 2018 coverage. 242,863 people had enrolled the year before, so enrollment declined by about 7 percent in 2018. Across all states that use HealthCare.gov, enrollment was about 5 percent lower in 2018 than it had been in 2017.
The enrollment drop was due to a variety of factors, including higher premiums for people who don’t receive premium subsidies, uncertainty about the state of the individual mandate (it’s still in place for 2018, but will be eliminated as of 2019), insurers exits from the marketplace, a much shorter open enrollment period (just over six weeks, as opposed to three months), and the Trump Administration’s decision to sharply reduce funding for exchange marketing and enrollment assistance.
Wisconsin will receive federal funding for reinsurance program to stabilize individual market
In March 2018, lawmakers in Wisconsin passed SB770, and Governor Scott Walker signed on March 28 (Act 138). The legislation directed the state to submit a 1332 waiver to CMS, seeking federal funding for a reinsurance program in Wisconsin (Democratic efforts to include amendments in SB770 calling for a Medicaid buy-in program and a “robust rate review” process were unsuccessful).
Alaska, Oregon, and Minnesota have already established reinsurance programs, and saw much more stable premiums in their individual markets for 2018. Wisconsin is one of several states that will adopt a similar program starting in 2019.
The Wisconsin Office of the Commissioner of Insurance published a draft of the 1332 waiver in March, with a public comment period running from March 13 to April 14. The state submitted the final waiver proposal to CMS on April 18. CMS opened another public comment period for Wisconsin’s reinsurance waiver proposal, which ran from May 9 to June 8 (comments they received are available here). The waiver proposal was approved by CMS on July 29, and will provide federal funding for the state’s reinsurance program for five years.
Under the reinsurance program, the state will start to pick up 50 percent of the cost of a claim once it reaches $50,000. The state will continue to pay 50 percent of the cost until the claim reaches $250,000.
Rate filings in Wisconsin were due in early July (before the federal funding for reinsurance had been approved), so insurers in Wisconsin had to submit two sets of rates for 2019 plans — one based on the reinsurance program being approved (with lower rates that reflect the decreased risk to insurers), and one based on the status quo, without reinsurance. Ultimately, the lower rates are being implemented, since the federal funding was approved.
Governor Walker’s office stated that average premiums for 2019 will be 3.5 percent lower in 2019 than they were in 2018, due to the implementation of the reinsurance program. Enrollment is expected to remain roughly similar to 2018 enrollment, whereas it would be expected to decline again in 2019 without reinsurance, as increasing premiums would be expected to result in more people who don’t get premium subsidies opting to leave the market.
The reinsurance program is projected to cost $200 million per year. $170 million of that is expected to come from the federal government, in the form of pass-through savings. Because premiums will be lower, premium subsidies (paid by the federal government) will also be lower, since they won’t need to be as large in order to make coverage affordable. The idea behind the pass-through funding is that the state gets to take the money that the federal government saves due to lower premium subsidies, and use it to fund the reinsurance program.
The state’s portion of the reinsurance program cost would come, in part, from savings due to the fact that the health insurance provider fee has been suspended for 2019. The money that the state won’t have to spend to cover the fee for the state’s group health insurance program (for state employees) and Medicaid managed care plans would instead be diverted to help fund the reinsurance program.
Lawmakers considered Medicaid buy-in but didn’t pass it; Democratic gubernatorial candidates express support
In the summer of 2017, Democratic state lawmakers in Wisconsin introduced legislation in the Assembly (AB449) and Senate (SB363) that would have allowed Wisconsin residents to buy into BadgerCare, the state’s Medicaid program (Medicaid in Wisconsin has not been expanded under the ACA, but it does cover people with income under the poverty level, so there is no coverage gap in Wisconsin). The idea was that BadgerCare 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, and the Democratic candidates who are vying to run against Republican Governor Scott Walker in 2018 have expressed support for the Medicaid buy-in. But the legislation faced an uphill battle in the Republican-controlled Wisconsin legislature, and did not advance in the 2018 session.
New Mexico lawmakers passed a similar bill in 2017, but Governor Brian Sandoval vetoed it. Colorado lawmakers are considering legislation that would direct the state to conduct a study on the feasibility and costs of a Medicaid buy-in program. But for now, there are no states where residents who aren’t eligible for Medicaid can buy into the program.
All counties have insurers for 2018
As rate filings trickled in around the country in the spring and early summer of 2017, there were initially 82 counties nationwide that didn’t have any exchange plans filed for 2018. One of them was Menominee County, Wisconsin. But in mid-August, the Wisconsin Office of the Insurance Commissioner announced that an insurer had agreed to offer exchange coverage in Menominee County, although they initially declined to say which insurer it was. Wisconsin Health News reported on August 22 that Security Health Plan is the new insurer that will cover Menominee County in 2018.
Molina was the only insurer that offered exchange coverage in Menominee County in 2017, and they exited the Wisconsin exchange altogether at the end of 2017 (details below). There were only 47 exchange enrollees in Menominee county in 2017, but all of them continued to have access to coverage for 2018. However, they had to switch to coverage offered by Security Health Plan during open enrollment (if they didn’t, the exchange automatically enrolled them in a Security Health Plan, but they also had a special enrollment period — through March 1, 2018 — during which they could pick a different plan from Security Health Plan).
Anthem, Molina, and Health Tradition Health Plans exited exchange at the end of 2017
Open enrollment for 2018 coverage began on November 1, 2017, and ended on December 15, 2017 (this same November 1 to December 15 enrollment window will be used in future years as well) All plans selected during open enrollment took effect January 1, 2018. Nearly every county in Wisconsin has at least two insurers offering plans in the exchange for 2018, and most of the southern part of the state has three or more insurers offering coverage for 2018.
Insurers that wished to offer individual market health plans in Wisconsin in 2018 had to 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 left the exchange at the end of 2017, and is only offering 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 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 offered individual market plans in the exchange in 34 of Wisconsin’s 72 counties in 2017, but unlike their strong market presence in most states, they only had 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 continued to offer coverage through 2017. They had 18,500 members in the individual market in 2017, about three-quarters of whom needed to select new coverage during open enrollment (the rest have grandmothered and grandfathered plans that were not terminated by Anthem).
Molina announced in August 2017 that they would exit the exchange in Wisconsin (and in Utah) at the end of 2017. Their total enrollment in Wisconsin, which included people with Medicaid and Medicare, was 130,000, and the Milwaukee Journal Sentinel reported that about 55,000 of those people had coverage in the individual market (it’s unclear what percentage of that population had on-exchange coverage, but it’s likely the majority; Molina did not market their ACA-compliant plans off-exchange for 2017, although some of their individual market enrollees likely had grandmothered and grandfathered plans).
Molina explained that Utah and Wisconsin were among the states where their marketplace performance had been “most disappointing” and that during the second quarter of 2017, Molina had spent 128 percent of the premiums collected in the Utah and Wisconsin exchanges on medical care (for reference, the ACA requires insurers to spend at least 80 percent of premiums on medical care as opposed to administrative expenses, but an amount of 100 percent or more is clearly unsustainable, as it means that the insurer is spending more on claims than it’s collecting in premiums, with no room for administrative costs at all).
Molina is continuing to offer one bronze plan off-exchange, in Shawano County. But the premium on that plan increased by 106.3 percent, and it is not being actively marketed. Molina projected that the plan would have just five enrollees in 2018, down from 163 members in that area in 2017.
Health Tradition Health Plans announced in June that they would exit the individual market altogether at the end of 2017. Based on Health Tradition’s 2017 rate filings, their membership in 2016 was fewer than 10,000 people. But all of their remaining individual market enrollees needed to select new plans for 2018.
Across the three insurers, there were about 75,000 people who need to select new coverage to replace plans that terminated on December 31, 2017.
Special enrollment period for people whose plan was terminated at the end of 2017
Involuntary loss of coverage is a qualifying event that triggers a special enrollment period. People who had on-exchange coverage in Wisconsin from one of the three exiting insurers (Anthem, Molina, and Health Tradition Health Plans) were mapped to a plan from a different insurer if they didn’t select their own replacement plan by December 15. But they were also eligible for a special enrollment period, through March 1, 2018.
For people who had off-exchange coverage that was terminated, the same special enrollment period applied, but there was no entity available to automatically map them to a different insurer if they didn’t pick their own plan.
For Anthem, Molina, and Health Tradition Health Plans members, the loss of coverage and associated special enrollment period applied to all on-exchange plans, and to most off-exchange plans:
- All ACA-compliant individual market policies from Health Tradition Health Plans were terminated at the end of 2017, and all members qualified for a special enrollment period.
- On-exchange Anthem plans were terminated. Off-exchange, all Anthem plans were terminated except one plan in Menominee County.
- On-exchange Molina plans were terminated. Off-exchange, all Molina plans were terminated except one bronze plan in Shawano County. As noted above, Molina expected enrollment in that plan to be just five people in 2018. People who had that bronze off-exchange Molina plan in Shawano County in 2017 did not have a special enrollment period (although most likely picked a different plan during open enrollment), but all other Wisconsin residents with ACA-compliant Molina plans did have a special enrollment period.
- In total, about 75,000 people in Wisconsin qualified for a special enrollment period triggered by loss of other coverage. Many likely picked a new plan during open enrollment, and some were doubt be happy with the plan that the exchange picked for them. But the special enrollment period continued through March 1 for those who wished to pick a different plan.
Gunderson merged with UW Health/UnityPoint
Gunderson Health Plan Inc. offers plans in the Wisconsin exchange in 2017, but there were no rate filings for Gunderson for 2018 on ratereview.healthcare.gov. However, earlier in 2017 there was a multi-insurer merger/acquisition that involved Gunderson. In July, UW Health and UnityPoint Health announced the completion of the merger, and their plans to integrate Gunderson Health System into their provider network.
Although Gunderson plans did not appear in the rate filings for 2018, Unity Health Plans filings were submitted. Unity already offered plans in the exchange in 2017, and their website notes that they are affiliated with UW Health/UnityPoint as the on-exchange insurance entity.
HealthPartners is also affiliated with UnityPoint. HealthPartners filed on-exchange plans for 2018, although their rate filings did not show up on ratereview.healthcare.gov for 2017. HealthPartners’ website notes that plans could be purchased in 2017 via the Wisconsin exchange, but their rate filing actuarial memo for 2018 indicated that their claims experience was based on the HealthPartners Midwest Choice Conversion Plan, which terminated at the end of February 2017.
2018 rates: 36% average increase, but subsidies offset for most exchange enrollees
On October 12, Wisconsin Insurance Commissioner, Ted Nickel, announced that the approved average rate increase for Wisconsin’s individual market — before any premium subsidies are applied — would be 36 percent for 2018. Nickel, who is not a fan of the ACA, said that “the ACA destabilized the Wisconsin individual health insurance market and federal health care reform efforts continue to face significant challenges. As a result, we are exploring our options available under the ACA Section 1332 Waiver for State Innovation.”
While average premium increases are certainly large in Wisconsin for 2018, the majority of Wisconsin exchange enrollees (83 percent) receive premium subsidies, which grew in 2018 to offset all or most of the rate increase for those enrollees. It’s also important to note that a substantial portion of the average rate increase is due to the fact that cost-sharing reductions (CSR) are no longer being funded by the federal government (Trump clarified on October 12 that the funding would end, but Wisconsin insurers had already based their rates for 2018 on the assumption that the funding would end, so no changes were necessary after the funding was official cut off; the Wisconsin Office of the Insurance Commissioner had directed insurers in July 2017 to revise their rates to reflect the assumption that CSR funding would not continue).
Insurers have to continue to provide CSR to eligible enrollees, regardless of whether the federal government pays them to do so. Since they won’t have federal funding to cover the cost in 2018, they’ve instead added the cost of CSR to silver plan premiums. The higher silver premiums mean that premium subsidies will be correspondingly larger in 2018 as well, but silver plan enrollees who don’t get premium subsidies might find better values if they consider bronze or gold plans instead.
11 Wisconsin insurers are offering exchange plans for 2018, with the following average rate increases (the original rate increases — before the state deemed it necessary to assume that CSR funding would not continue — are also listed. 2017 enrollment totals are listed for plans that have made them available; if the insurer offers plans both on and off the exchange, the enrollment total is for the combined membership):
- Aspirus Arise: 33.26% (Aspirus Arise HMO); 33.16% (Aspirus Arise POS). Aspirus Arise had previously filed an average rate increase of 15 percent (note that Aspirus Arise is a separate entity from Arise Health Plan).
- Common Ground Healthcare Cooperative: 63.03 percent (29,030 members). The original average proposed rate increase was 20.3 percent
- Children’s Community Health Plan: 23.18 percent (averages vary from 18.2 to 42.2 percent). The initial proposed rate increase was 10 percent (3,000 members)
- Dean Health Plan: 49.68 percent (53.69% for the EPO, and 48.52% for the HMO). Dean’s initial proposed average rate increase was 28 percent (36,290 members)
- Group Health Cooperative of South Central Wisconsin: 13.8 percent or 32.3 percent, depending on the product (averages vary from 7.9 percent to 49.9 percent). Group Health Cooperative’s filing summary notes that “For 2018, the environment for ACA plans is newly uncertain, with communication on reduced enforcement of the individual mandate and curtailed marketing of ACA exchanges around open enrollment. Additionally, cost share reductions, whereby lower income individuals are exposed to lower member cost sharing than priced for in the plan design, is projected to lose its federal funding in 2018. These additional costs to the GHC-SCW are contributing significantly to the large increases for the On-exchange Silver plans.” This was their original filing, and they did not have to make any significant changes later in the summer, as they had already accounted for the lack of CSR funding (2,049 members)
- HealthPartners Insurance: 20.58 percent (1,500 members). This was HealthPartners’ original filing, and was already based on the assumption that the federal government will not fund cost-sharing reductions for 2018. It’s noteworthy, however, that HealthPartners’ off-exchange average rate increase is only 11.4 percent.
- Medica Health Plans of Wisconsin: 30.23 percent (6,997 members). The original proposed average rate increase was 19.2 percent. Medica’s filing notes that while the plans will be available on-exchange in 2018, they do not intend to actively market their individual plans off-exchange. The filing also indicates that the rate increase is partially based on an “unprecedented amount of uncertainty and risk inherent in the marketplace.“
- MercyCare HMO Inc: 35.1 percent (5,212 members). The original proposed average rate increase was 17.4 percent. The revised filing indicates that 16.4 percentage points have been added to the average rate increases for silver plans, to cover the cost of CSR.
- Network Health: 54.73 percent (71.21% for NE WI, and 48.71% for SE WI). The original proposed average rate increase was 24.7 percent (8,840 members).
- Security Health Plan of Wisconsin, Inc: 29.72 percent. The original proposed average rate increase was just 3.5 percent (28,352 members)
- Unity Health Insurance: 34.9 percent (2,196 members). Unity’s mid-July filing confirms that the cost of CSR has been added to silver plans, but it appears that the original filing (dated in May) also assumed that CSR funding would not continue, as it had virtually the same average rate increase, at 32.2 percent.
As is always the case, the approved rate increases do not account for premium subsidies. The ACA’s premium subsidies grow to keep pace with premiums, and are designed to keep the after-subsidy premium of the second-lowest-cost silver plan at an affordable level. 83 percent of Wisconsin exchange enrollees are receiving premium subsidies (a number that is expected to grow in 2018), and their subsidies will offset all or most of the rate increases (in fact, after-subsidy rates will be slightly lower in 2018 for people whose income remains the same). But exchange enrollees who aren’t eligible for subsidies, as well as everyone who has coverage off-exchange, will have to shoulder the full rate increase for 2018.
It’s clear from the rate filings that a significant portion of the rate increases is due to the fact that cost-sharing reductions won’t be funded by the federal government in 2018 (this was uncertain in July and August when revised rates were filed with that assumption, but is now certain), and on an expectation that the Trump Administration will not adequately enforce the individual mandate. Although the higher rates that result from that uncertainty will be largely mitigated by larger premium subsidies for those eligible, there is no such mechanism to protect people whose income exceeds 400 percent of the poverty level, which certainly encompasses a broad swath of the middle class.
Wisconsin and the future of the ACA
The future of the individual health insurance market is uncertain. Republicans in Congress have been unsuccessful in their attempts to repeal and replace the ACA, so for the time being, it remains intact (The House passed the American Health Care Act in May, but in July the Senate failed to pass three different versions of the legislation: the Better Care Reconciliation Act, the Obamacare Repeal Reconciliation Act, and the Health Care Freedom Act, and eventually pulled the Graham-Cassidy amendment in September when it was clear that they didn’t have enough votes to pass it).
However, the Trump Administration — along with the GOP’s legislative efforts to derail the ACA — has created considerable uncertainty in the insurance markets (both on and off-exchange), and there’s a lot that the Trump Administration can do to hamstring the ACA without any action on the part of Congress. The result of all of this is that premiums for 2018 are considerably higher than they would otherwise be, and insurers in many states — including Wisconsin — are leaving the exchanges at the end of 2017.
The fact that the Trump Administration has cut off funding for cost-sharing reductions (CSR) was a major factor in the rate increases for 2018. 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 through September 2017, the reimbursements were funded.
But the Trump Administration announced decisively in October 2017 that the funding would end. Wisconsin insurers had already filed revised rates in the summer to account for that eventuality — as indicated above, they’re generally much higher than the original round of rate increase proposals that insurers filed earlier in 2017. Consumers are generally protected from the impact of the CSR cost being added to premiums, since it was added to silver plan premiums and resulted in premium subsidies being much larger than they would otherwise have been.
But there are other changes on the horizon that could affect the individual market and premiums in future years. The individual mandate penalty will be eliminated as of 2019, and the Trump Administration has proposed expanding access to short-term plans and association health plans. All of those factors are likely to result in fewer healthy people obtaining coverage in the ACA-compliant market, particularly among people who don’t qualify for premium subsidies. When fewer healthy people purchase coverage, the result is higher premiums and less stability in the market. But Wisconsin is hoping that the proposed reinsurance program (details above) will serve to stabilize the individual market in 2019 and beyond.
Wisconsin Insurance Commissioner supported AHCA & return to high-risk pools
The day after House Republicans passed the American Health Care Act (AHCA), Wisconsin Insurance Commissioner, Ted Nickel, voiced his support to the legislation. In a May 2017 MacIver Institute article, Nickel welcomed the potential return to high-risk pools under the AHCA, and waxed about the benefits of Wisconsin’s pre-ACA high risk pool, the Health Insurance Risk Sharing Plan (HIRSP), which closed once health plans in the private market became guaranteed-issue, regardless of medical history.
Nickel stated that for three decades, HIRSP provided solid coverage to Wisconsin residents, and indicated that at least some of those residents are worse off under the ACA (it’s noteworthy that people who qualify for significant premium subsidies in the exchange are likely paying lower premiums now than they were under HIRSP, but not everyone qualifies for substantial subsidies).
HIRSP covered roughly 24,000 people in the pre-ACA days when health insurance was medically underwritten in the private market, making it among the largest high-risk pools in the nation. And premiums were only about 20 percent to 30 percent higher than standard rates. That’s much better than most states’ high-risk pools, however, as high-risk pools typically had rates that were at least 50 percent higher than standard rates, and in some states, they were double the standard rates.
Governor 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 have allowed states to opt out of the ACA’s essential health benefits requirements; they would also have been allowed to let insurers charge premiums based on applicants’ medical history if the applicant had a gap in coverage during the prior year). But by the next day, after significant backlash over the potential evisceration of protections for people with pre-existing conditions, Walker appeared to backtrack on his position, saying that the state was “not looking to change” the current pre-existing condition protections.
All of that is a moot point, since the AHCA was never enacted. But it does highlight the health care reform positions of Wisconsin’s governor and insurance commissioner.
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.
By March 2017, effectuated enrollment in Wisconsin’s exchange stood at 216,355 (effectuated enrollment is always lower than the number of people who initially sign up, since some people never pay for their coverage, and others cancel their coverage very early in the year).
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.
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.