Now that open enrollment is winding down, the execution phase for 2014 is in full swing and the planning cycle for 2015 will be wrapping up soon. After that, insurance companies and their state regulators will build for 2015 implementation. So what should we be seeing in the next month or so.
1) Cleaning out the pipeline.
The first task is to complete open enrollment for on-Exchange policies. All people who signed up on Healthcare.gov but could not complete their application by last night still have a chance to finish their application. If they checked their blue box, they have until mid-April to complete their application. This is a fairly simple task for all entities. The website should have breathing room after yesterday’s peak load, navigators will be able to rest for a couple of minutes, and enrollment counselors at the call center will have a chance to talk people through the process. Insurance companies will have sufficient time to process enrollments on the dreaded 834 file and get ID cards out for May 1st.
2) Continue enrollment for Medicaid and qualifying life events
Enrollment does not stop. People who are eligible for Medicaid or CHIP can enroll at any time. We should expect to see the Expansion states to steadily add people to Medicaid as informal social networks as well as formal recruiting networks will pull more people in. People who don’t qualify for Medicaid or CHIP can still buy new policies on the Exchanges if they have a major life event. A major life event can be the start or end of a marriage, birth, adoption, or death of a family member, a big move and a big change in income. I’ll write more about this later this week. A major life event is a “qualifying event” which means people have a 30 day window to change their insurance situation to match the new personal situation. I don’t expect a ton of movement, but I do expect a steady trickle of changes and additions.
3) States must decide what they want to do for 2015
States face a few major decisions. The first is how they want to manage their Exchange for 2015. State built exchanges can continue to build out capability, or like Maryland, they can junk their system and buy proven technology from Connecticutt. State built exchanges have the option to go to healthcare.gov. States already on Healthcare.gov have the choice to continue on with the Federal Exchange or build/buy their own. As anti-asshole Adler insurance, I hope states that have a Democratic governing coalition but are on Federal Exchanges move to state run Exchanges. Additionally, states must decide what the minimal standards for network adequacy are for Exchange qualified plans and make the choice as to whether or not they want to actively manage competition like California or act as a clearinghouse like the Feds.
4) Health insurance companies must decide what 2014 looks like
Initial plans for 2015 are due to the states and the Feds in only a couple of weeks. Pricing for 2015 is a soft target right now as the actuaries and underwriters don’t have a complete data set. They won’t have a complete data set until May, and even then there is certainty that the April and May effective date policies are held by people who are statistically seperate from the people who signed up in 2013. There are some data pooling services available for actuaries to make a guess as to what actual costs will look like this year, and what they could look like next year, but there are significant assumptions. Insurance companies will need to make a set of decisions as to what 2014 looks like in the next couple of weeks.
5) Health insurance companies file for 2015
Health insurance companies take a look at the results of Step 3 and 4 to make their plans for 2015. Insurers have the option of withdrawing from markets, staying the same, modifying offerings or adding products. I’m assuming most insurers are modifying and adding new products and new service areas. I am also assuming (based on co-ops and the fact that open enrollment was successful) that we should see more insurance companies enter the Exchange market. All companies need to file their proposed rate structures to their state regulating entities in the next few months. Companies that are adding or changing plans need to file their plans and networks to their state regulators in the next six to eight weeks. Over the summer, the state regulators and insurers will play ping pong until there is a mutually satisfactory set of proposals or proposals are withdrawn.
These are the five big moving parts for this spring. There will be more, but these are the important changes.