CSR Allocation methods for 2019 On-Exchange plans

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.

The Congressional Budget Office assumed that almost every state and insurer would Silver Load for 2019.

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.

10 replies
  1. 1
    satby says:

    I appreciate these posts.
    Have you ever described what you feel would be the least disruptive path to universal health care coverage in this country? I think you’ve said it would be more like Medicaid for all than Medicare for all, but wouldn’t that run into the prejudice most Americans express for “poor peoples” programs and how resistant folks would be to be included in it?

  2. 2
    Butch says:

    Checked with my agent recently because I’d really like to move from the current underwritten plan to something that complies with the ACA, and once again, at least here in the rural Upper Peninsula, the premiums would exceed my current monthly income. (Not eligible for subsidy because of pre-layoff income.)

  3. 3

    @satby: I’m slowly drafting a piece about what I see as plausible. It is a highly contingent piece that may never see the light of day.

  4. 4
    WaterGirl says:

    Apologies for going OT, but I just got a text from a friend whose husband is in the hospital with “Crazy high ammonia levels in his blood with no explanation for it”. He is semi-conscious.

    Has anyone here ever heard of that? Does anyone know what/how that happens?

  5. 5
    Amir Khalid says:

    First thing that came to my mind was kidney failure. Has that been ruled out?

  6. 6
    WaterGirl says:

    @Amir Khalid: I’m sure it hasn’t.

    He got an e coli infection earlier this year that compromised his heart and his kidneys, but he has been stable. He had liver issues a couple of years ago, and he was on the transplant list for a year or two but they took him off the list a year ago because he was doing so well on the meds. He is also diabetic.

    But this ammonia thing came out of the blue.

  7. 7
    Brachiator says:

    On my commute and just found an interesting story in USA Today about Medicare Advantage plans.

    Health care experts widely expected the Affordable Care Act to hobble Medicare Advantage, the government-funded private health plans that millions of seniors have chosen as an alternative to the original Medicare.
    To pay for expanding coverage to the uninsured, the 2010 law cut billions of dollars in federal payments to the plans. Government budget analysts predicted that would lead to a sharp drop in enrollment as insurers reduced benefits, exited states or left the business altogether.
    But those projections proved wrong.
    Since 2010, enrollment in Medicare Advantage has doubled to more than 20 million, growing from a quarter of Medicare beneficiaries to more than a third.

    The story notes that 10,000 people a day age into Medicare range.

    The complexities of health insurance issues are staggering. And yet the story notes how insurance companies are making money from these Medicare Advantage plans. And obviously there is strong demand for them.

    Sorry, but having trouble creating link ref with my mobile browser.



  8. 8
    WaterGirl says:

    @Brachiator: I always thought Medicare Advantage was good for the insurance companies but not so good for the enrollees.

    Is that still true?

    Both my sisters and their husbands have chosen that, though, whatever that shows. Both the RW religious sister and the other sister who looks up for 45 minutes before the election and decides who vote for.

  9. 9
    Brachiator says:

    @WaterGirl: I don’t know how good these plans are, but then again, it seems strange to me that regular Medicare does not cover vision and dental. This is obviously needed by many people.

  10. 10
    WaterGirl says:

    @Brachiator: Agreed. But you can buy those separately without going to Advantage.

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