Obamacare enrollment at vaccination sites Part II: Navigators on their own, mostly

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A month ago, I posited that the impressive drive to vaccinate all U.S. adults is also a golden opportunity to insure the uninsured. 

Vaccinations are free to all, but in the vaccination process the uninsured must identify themselves as such. An estimated 11 million uninsured are eligible for marketplace subsidies (now often zeroing out premiums entirely), and another 7 million for Medicaid. The emergency Special Enrollment Period launched by the Biden administration on February 15, running through August 15, opens the enrollment door to anyone who's uninsured and lacks access to other coverage -- and coincides with the vaccination drive. 

As noted in the prior post, while some assister groups have done outreach at vaccination sites, and at least a couple of states have supported such efforts to some degree, the initiative has come mainly from the assisters themselves (generally operating on a shoestring through the lean Trump years), not government agencies, and efforts have been scattered.  

That is accurate. CMS confirmed to me that while the agency gives assister groups vaccine information to disseminate, "CMS...has not promoted or organized any official Marketplace outreach or enrollment events in conjunction with any COVID-19 vaccination site or event."

HHS devotes $4.8 billion to COVID-test the uninsured. P.S. How about insuring them?

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HHS announced today that it is dedicating $4.8 billion in American Rescue Plan funds to reimburse providers for providing Covid-19 testing to the uninsured, at no cost to the uninsured patient. That's a continuation of a program initiated last spring. So far, $2.5 billion has been allocated by the Health Resources and Services Administration (HRSA) for such reimbursement.

Am I letting a current preoccupation distort my vision in seeing something of a lost opportunity (and irony) in this HHS statement?

There are approximately 29 million uninsured individuals living in the United States. While this administration has been focused on decreasing the uninsured rate, as evidenced by the more than 1 million people who have enrolled into quality health coverage through the Special Enrollment Period (SEP), much work remains. By ensuring programs like the HRSA COVID-19 Uninsured Program remains adequately funded, this administration is removing cost impediments so anyone exposed to COVID-19 may seek appropriate testing and care.

The funding announced today is dedicated to COVID-19 testing. HRSA also helps uninsured individuals’ access COVID-19 treatment and vaccinations through the COVID-19 Uninsured Program.  The program reimburses providers at national Medicare rates for providing these services.

Can free silver close much of the "upper coverage gap" in nonexpansion states?

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Update, 5/4/21: New data via the CMS state-level public use files for 2021 shows that enrollment at100-138% FPL in nonexpansion states increased dramatically in 2021. See this post for an update.

The principle harm wrought by states that refused to enact the ACA Medicaid expansion after the Supreme Court rendered expansion optional is well known. More than 2 million people with incomes below 100% the Federal Poverty Level (FPL) in the fourteen states that have not yet enacted the expansion are uninsured and eligible neither for Medicaid nor for ACA marketplace subsidies, according to KFF estimates.

A secondary, less recognized harm is imposed on nonexpansion state residents whom the ACA intended to be at the upper end of eligibility for Medicaid, those with incomes in the 100-138% FPL range. In nonexpansion states, residents in this income category are eligible for marketplace subsidies. Until the American Rescue Plan Act (ARPA) was enacted last month, a benchmark silver plan with strong Cost Sharing Reduction would cost enrollees in this income range 2% of income, or a maximum of $29 per month for a single person with an annual income of 138% FPL (currently $17,609). Thanks to ARPA, benchmark silver is now free for enrollees in this income range (and up to 150% FPL).

On paper, even the pre-ARPA offering doesn't sound like a bad deal. The actuarial value of silver in this income bracket is 94%; the average deductible is around $200, and the average annual out-of-pocket maximum is about $1100. But takeup, as I noted in my last post, has been poor. Recent KFF estimates of the uninsured in this income range in nonexpansion states, set against actual enrollment at this income level in 2020, suggest that only about 53% of those eligible have actually enrolled. Take Florida out of the equation, and the takeup rate drops to 43%. 

In this post I'd like to flip the script: what if we make Florida the equation, rather than taking it out? Something in the state's marketplace is going relatively right, and has since the launch of the ACA marketplace.  In Florida, to the extent KFF's estimates of the uninsured are on target, 72% of subsidy-eligible people in the 100-138% FPL bracket are enrolled. That exceeds takeup at 100-138% FPL in the other 11 nonexpansion states tracked by KFF* by almost 30 percentage points. If those states attained Florida takeup rates, the ranks of the uninsured in this category would drop by over 700,000 -- about half of them in Texas (Figure 1).

The ACA marketplace in year 7: The navigators' view

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The Affordable Care Act's health insurance marketplace, born on January 1, 2014, isn't a baby any more. In fact you might say it's reached maturity.

Like many children, it's disappointed its parents somewhat, insuring about half as many people as the Congressional Budget Office forecast when the ACA was passed. It's withstood multiple legislative and administrative assaults from Republicans and survived a half dozen near-death experiences via  repeal bills and court challenges to its constitutionality, one of which still looms. The marketplace's lower-profile twin, the ACA Medicaid expansion, has been more successful -- insuring more people more thoroughly for less money.

But the individual market for health insurance reshaped by the ACA is beginning its seventh year of offering comprehensive health insurance to anyone who lacks access to other insurance without regard to their medical history or current health. The ACA-compliant market serves about 13 million people, about three quarters of them subsidized, with the federal government paying about 86% of subsidized enrollees' monthly premium on average.

As the nation is faced with a major pandemic-induced recession, the marketplace and ACA Medicaid expansion stand poised to insure millions who lose employer-based insurance.

Call the midwife

There is a set of marketplace midwives who were in at the birth and have continued their intimate engagement: enrollment assisters, including nonprofit navigators established by the ACA; nonprofit and often volunteer Certified Application Counselors (CACs); and for-profit brokers who work in the individual market.

Covered California to middle-class enrollees: There (may be) gold in them thar hills

Update (!) Oct. 11, 2017: CoveredCA has gone live with  its 2018 plan preview tool and has implemented the CSR surcharge discussed below -- 12.4% added to silver on-exchange plans only. That makes gold cheaper than silver in some areas, and CoveredCA is indeed in some cases highlighting gold plan offerings ahead of silver.

Back on August 1 Covered California, the California ACA exchange, announced a proactive approach to enable health insurers to cope with the uncertainty over whether the Trump administration (or Congress) would guarantee them continued reimbursement for Cost Sharing Reduction subsidies.

Insurers would file rate requests under the assumption that CSR will continue to be reimbursed. If reimbursement was not guaranteed by a certain date, however, a surcharge (later pegged at 12.4%) would be added to silver plans sold on-exchange. CSR is available to enrollees with qualifying incomes only if they select silver plans, and only if they buy on-exchange. ACA-compliant silver plans sold off-exchange would not include the surcharge. That surcharge is likely to be triggered on or around October 11, CoveredCA tells me (postponed from an original target of Sept. 30).

The likely results have been widely noted (e.g., here). Off-exchange, plan pricing would remain proportionate to the actuarial value offered at each metal level. On-exchange, the only buyers of silver plans should be those with incomes up to 200% of the Federal Poverty Level, for whom CSR raises the value of silver plans roughly to that of platinum.