Silver-loading, the practice of insurers and states putting all the cost of terminating Cost Sharing Reduction (CSR) payments into on-Exchange Silver plans is safe for the year:
HHS won’t ban silver-loading this year, Azar admits after being pressed.
No time to write broad-loading regs for 2019 plan year.
— Alex Ruoff (@Alexruoff) June 6, 2018
I am worried about “No time to write broad-loading regs for 2019…” as there is plenty of time to write those regulations. Louise Norris, Charles Gaba, Andrew Sprung and I wrote about our concerns regarding a Broad Load regulation in Health Affairs last month:
If CMS mandates broad loading, there will be significant distributional consequences. Most likely, a uniform, percentage surcharge will lead to very few if any counties having a single gold plan that is less expensive than the benchmark plan. In 2017, five counties using Healthcare.gov had at least one gold plan less expensive than the benchmark. Bronze plans will be modestly discounted relative to the benchmark, but the steep discounts generated by silver loading will disappear.
Detailed, actuarial simulations will be needed, but we anticipate significantly lower enrollment if states are required to spread the cost of CSRs to all plans instead of loading the costs only onto silver plans…
That is a concern for 2020. It is no longer a concern for 2019.