Saturday, February 06, 2016

CMS Open Enrollment error in New York (updated, with CMS correction)

[Update 2/11/16: CMS has made  a correction -- see below.]

CMS's ACA enrollment snapshot for the final week of Open Enrollment 2016 contains an error, bolded below:
It is also worth noting that nearly 400,000 people signed up for New York’s new Basic Health Program, along with about 33,000 people who signed up for Minnesota’s Basic Health Program, during this Open Enrollment. Basic Health Programs are state based programs supported by the Affordable Care Act that provide health insurance coverage to low income individuals who would generally otherwise be eligible for qualified health plans [QHPs]. In fact, about 300,000 of the New York Basic Health Program enrollees for 2016 are people who enrolled in Marketplace coverage for 2015 and were included in last year’s Marketplace total plan selections.
Enrollees in New York's Essential Plan, the BHP formed under the auspices of  the ACA, come from two pools. The first is those who lack access to employer-sponsored plans and have incomes between 139% and 200% of the Federal Poverty Level (FPL). If the Essential Plan did not exist, these people would be eligible for subsidized QHPs in New York's private marketplace. Some of them were in fact enrolled in QHPs in 2015, but not 300,000.

The second pool is comprised of legally present non-citizens with incomes anywhere from 0-200% FPL who are subject to the federal "5-year bar" on Medicaid eligibility -- that is, you're not eligible for Medicaid until you've been in the country for 5 years. The ACA allows those subject to this Medicaid bar to buy subsidized QHPs even if their income is below the Medicaid eligibility threshold for those not subject to the bar.  In New York, however, those subject to the 5-year bar who otherwise meet Medicaid eligibility criteria are eligible, because a court order mandated the state to cover them. Forming the BHP enabled the state to transfer these Medicaid enrollees to a federally funded program.  In April 2015, the state did just that, transferring 225,000 lawfully present non-citizens from state-funded Medicaid into the newly formed Essential Plan (open only to this group until January 1, 2016).

As for last year's QHP enrollees, only about 150,000 were likely eligible for transfer. As of the end of Open Enrollment 2015, according to the state's enrollment report, 415,352 New Yorkers were enrolled in QHPs. 74% of them were subsidized, and 54% of those, or 40% of the whole, had incomes under 200% FPL, which would qualify them for the Essential Plan in 2016. By June 30 of last year, total QHP enrollment was down to 370,058, suggesting that by that point, about 148,000 enrollees would be eligible for the Essential Plan in 2016 if their income did not change [see Update II below].

Judging from the experience of states that belatedly expanded Medicaid, however, it's likely that a decent percentage of 2015 QHP enrollees whose incomes now qualify them for the BHP (which has much lower premiums and cost-sharing) were auto-enrolled in their private plan for 2016. If they do nothing, they're presumably still enrolled in that plan -- unless the state barred auto-enrollment for those who reported a 2015 income under 200% FPL (I'll check that this coming week).

As of January 25, New York State of Health, the state ACA marketplace, announced that 356,000 people were enrolled in the Essential Plan. On Feb. 4, CMS pegged the total at "nearly 400,000." Of those, it would appear that at most 175,000 were outside the legally present non-citizen category. That 175,000 is doubtless a mix of 2015 QHP enrollees and new enrollees with incomes between 139% and 200% FPL -- as well as, perhaps, a number of previously uninsured legally present immigrants with incomes under 139% FPL.

NYSOH's Jan. 25 release pegged QHP enrollment at 260,000, down from 370k at mid-year 2015. That makes sense, and suggests that, assuming further attrition between June and December, perhaps 100,000 enrollees (or less) transferred to the Essential Plan.

I look forward to getting corrected numbers from NYSOH and/or CMS in the coming week(s).

UPDATE 2/11/16:  CMS has made the following correction (now visible in the enrollment snapshot):

On January 31, Open Enrollment for 2016 coverage ended, with about 12.7 million plan selections through the Health Insurance Marketplaces. Of the 12.7 million consumers enrolling in Marketplace coverage, over 9.6 million came through the HealthCare.gov platform and 3.1 million selected a plan through State-based Marketplaces. It is also worth noting that nearly 400,000 people signed up for New York’s new Basic Health Program, along with about 33,000 people who signed up for Minnesota’s Basic Health Program, during this Open Enrollment. Basic Health Programs are state based programs supported by the Affordable Care Act that provide health insurance coverage to low income individuals who would generally otherwise be eligible for qualified health plans. In fact, about 160,000 of the roughly 300,000 New York Basic Health Program re-enrollees for 2016 were enrolled in Qualified Health Plans last year and were included in last year’s Marketplace total plan selections.1

1This sentence was updated on 02/11/2016 to clarify the 2015 enrollment status of New York Basic Health Program enrollees.
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It seems to me that 160,000 is more likely the number of Essential Plan enrollees whose incomes would have qualified them for QHPs had the BHP not been launch, but that not all of them were likely 2015 QHP enrollees.

UPDATE II, 2/15/16: Charles Gaba notes that that CMS's effectuated enrollment snapshot for Sept. 30, 2015 (released 12/22; I missed it) had New York QHP enrollment down to 357,000, which would bring potential BHP enrollment from this pool down to about 140,000 (if the attrition was proportionate among the income groups buying QHPs).

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