Is enrollment surge on GetCoveredNJ driven by off-exchange migration? Maybe not.

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Liberty State Park, Jersey City, NJ

New Jersey's Department of Banking and Insurance (DOBI) reports that enrollment in health plans on GetCoveredNJ, the state's ACA exchange, was up more than 25% as of December 5 compared to the same time last year. That may be the largest one-state year-over-year surge during an Open Enrollment season in which enrollment was up about 9% nationally as of Dec. 8. 

New Jersey has a large off-exchange individual market, which in 2020 accounted for 30% of enrollment in ACA-compliant plans (94,885 out of 316,580 total enrollments as of Q1 2020). The surge in on-exchange enrollment may provide a hint as to the extent of migration from off-exchange to on-exchange driven by the American Rescue Plan Act's removal of the income cap on subsidy eligibility. Since April of this year, premiums for the benchmark (second cheapest) silver plan have been capped at 8.5% of income, regardless of how high the income is. New Jersey, moreover, layers its own supplemental subsidy on top of the federal APTC. At high incomes, NJ kicks in $100/month per person, up to an income of 600% FPL. This subsidy, like the federal one, is only available on-exchange.

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As of the end of Open Enrollment for 2021 last January (prior to the ARPA subsidy boost, implemented in April of this year), 79% of enrollees on GetCoveredNJ were subsidized. Thus far, 85% of enrollees for 2022 are subsidized (see GetCoveredNJ's Week 5 snapshot).

Enrollment as of the end of Week 5 of OE this year (286,955) exceeds enrollment as of the end of OE for 2021 (269,560) by 6%.  Subsidized enrollment thus far this year (243,912) exceeds subsidized enrollment as of the end of the last OE 213,233 by 30,679, or 14%. Of course, all of that shift could come from on-exchange enrollees who were unsubsidized last year but became subsidy eligible when ARPA passed (or from people who were not in the individual market last year and who are subsidized but would not have been pre-ARPA).

In fact it does not look like there's been a large migration from off-exchange to on-exchange in New Jersey. The year-over-year increase in the percentage of on-exchange enrollment that is subsidized is actually fairly modest, given the removal of the income cap on subsidies. It's a wealthy state, and a fair number of on-exchange enrollees still don't qualify for subsidies. That's the case when unsubsidized coverage costs less than 8.5% of income, and income exceeds 600% FPL.

To the extent that a significant number of off-exchange enrollees may have moved on-exchange, they would likely have done so during the emergency Special Enrollment Period that in New Jersey ran from February 15 to December 15.  As of the end of August, 63,028 New Jerseyans had enrolled via SEP.  During OE this year, in New Jersey as nationally, year-over-year enrollment gains are largely consolidating the gains from the emergency SEP (which ran from Feb. 15 to Aug. 15 in the 33 states using the federal exchange, and to varying extents in the 15 state-based marketplaces). During OE for 2022 through Week 5, new enrollments are actually down compared to the same period in OE for 2021, from 20,000 to 13,000, though active renewals have nearly doubled, to 28,000 from 15,000. 

DOBI reports off-exchange enrollment (along with on-exchange) on a quarterly basis, but with a lag: individual market data so far runs only through Q4 2020. We will have to wait a while to see the effect of ARPA on the state's off-exchange market.