Open Enrollment for the ACA starts on Thursday morning. Of the three Open Enrollments that have been partially or fully administered by the Trump administration, this seems likely to be the most boring. We are in a steady state of predictable policy with few, if any shocks. Yesterday, at the Health Affairs blog, I laid out my thinking on the major factors that will drive enrollment changes on Healthcare.gov.
There are some drivers that should increase enrollment. These include
- More Silver loading
- $0 premium plans are available in numerous counties at incomes over 200% FPL.
- More insurers entering markets
- Catastrophic plans are increasingly accessible
- Lower premiums for the non-subsidized due to 1332 waivers
- More broker engagement
There are also major downward drivers. Policy has changed.
- No individual mandate
- More underwritten plans
- Compressing the Silver Gap in Philadelphia and other regions with very large gaps in 2018.
- Less navigator funding
And then there is the background noise. We know that the federal messaging is fundamentally anti-enrollment. We know that there will be little positive enrollment comments from senior government officials. We know that the open enrollment period is six weeks. We know all of that, and these are constants. I think these items are baked into the cake from 2018’s open enrollment numbers so I am not expecting too much to change there.
The big tensions will be the removal of the individual mandate driving enrollment down and the continual proliferation of much better deals due to CSR termination for the subsidized population driving enrollment up.
What if the judge issues an order in Texas v US granting Trump’s request that community rating and guaranteed issue be invalidated and the court of appeals does not immediately stay the order? I seem to recall at least some contracts between states/feds and insurers concerning exchange access allow insurers to terminate participation upon the occurrence of specified events. If such an order is issued and not stayed, is there a more-than-remote possibility insurers will abandon the exchanges and stop guaranteed issue of community rated policies?
@Ken: That outcome is not a termination clause in the QHP contracts.
I would be shocked if the ink is dry on a stay request at the Appeals Court when a stay is issued.