Cost Sharing Reduction (CSR) payments are still not being made. Insurers are still obligated to provide these benefits to income and plan selected qualified individuals. Insurers have three basic strategies to be made whole for their actual claims expense:
- Do nothing
- Broad Load the CSR increment into all plans as a fixed surcharge
- Silver Load the CSR increment onto only Silver plans
- Silver load the CSR increment onto only on-Exchange Silver plans
In 2018, insurers were all over the place for their on-Exchange strategies. Most insurers and states Silver Loaded. This led to higher enrollment that otherwise would have occurred in the 200% to 400% Federal Poverty Level as well as a shift out of Silver plans. In 2018, six states Broad Loaded, and three states did nothing. Five states had insurers choose a strategy which led to some very interesting mixtures in Georgia, Texas and Illinois that invite county line discontinuity dissertations.
This is not quite right. Charles Gaba, and Louise Norris have updated our tracking sheet for 2019.Five states changed strategy. New Mexico went from an anything goes strategy to Silver loading. Vermont and North Dakota did nothing for CSR in 2018 and now are Silver Loading while Delaware and Colorado are switching from a Broad Load to Silver Load. No state that Silver Loaded last year switched strategies. We are still waiting for clarity in Illinois, Georgia and Texas, big states where multiple strategies were used. Indiana, West Virginia, Mississippi and Oklahoma are still Broad Loading while Washington DC has not been explicit about any CSR load as it is nearly irrlevant as Medicaid eligibility goes to 215% FPL.