Since open enrollment in the federal marketplace is only weeks away, I intended to use this week’s column as a pitch for engagement in enrollment efforts. I still will. However, several developments late this week deserve exploration since they could have implications for the marketplace in the short- and long-term.
Yesterday, President Trump signed an executive order taking a jab at the Affordable Care Act’s product and marketplace provisions. Today, he threw a second punch at Healthcare.gov and state marketplace insurers and participants, by directing his administration to cease cost-sharing subsidies, noting that they were illegal because they were specifically denied by Congress, but implemented by President Obama anyway. This legal wrangling may continue for months to come.
Meanwhile, open enrollment begins Nov. 1. The items included in Trump’s executive order will require regulatory action that generally precludes immediate implementation. The cut to subsidies — if it holds — would have implications for current individual marketplace insurers, and could affect enrollment and insurer participation in the 2018 plan year.
To some extent, the announcements aren’t surprising. In August, the Trump administration slashed funding for marketplace product advertisement during open enrollment by 90 percent. Funding for navigators to assist consumers in purchasing coverage in the marketplace was reduced as well. And, the subsidy issue was being litigated in court.
We can’t know yet whether association health plans will be successful. Theoretically, they could boost small employer options for coverage. However, there have been questions about whether individuals — especially self-employed individuals — could participate. Another question is related to the quality of health plans that individuals would purchase under the order’s short-term insurance component. Although association health plans are likely to include most or all of the ACA’s essential benefits, the short-term plan components are not. It may very well be the middle of next year when we see actual regulations implementing this program. That’s when we will really understand the impact of this action.
The announcement most likely to challenge the 2018 Marketplace is today’s announcement related to cost-sharing. Although the months of uncertainty has led most insurers to hedge against the subsidies and risk pool imbalance, it can’t be known in advance what effect this week’s announcements, coupled with the earlier assaults on advertising and advising, will have on consumers. What we do know is that for some health plan offerings, premiums may increase. But for those who receive subsidies for their insurance, the change may be invisible since the federal government — with its other hand — will be picking up much of the premium increase. Those who will be significantly impacted are consumers who buy insurance on the federal marketplace and don’t receive a federal tax subsidy.
The background noise of the past two days tends to drown out the key issue for hospitals — that we have a tremendous stake in the outcome of open enrollment. This week’s one-two punch shouldn’t deter our efforts to reach out to current enrollees and eligible Missourians who are not currently participating. We must remain focused on that mission and continue to prepare to help those who need insurance coverage.
The Missouri Foundation for Health continues to lead efforts to educate Missourians through the Cover Missouri program. MHA is partnering with MFH, and adding resources to our Enroll Missouri page.
With all of the uncertainty, open enrollment will require all hands on deck. We’ll be sharing additional resources as they emerge.
Let me know what you’re thinking.
Herb B. Kuhn
MHA President and CEO
In This Issue
President Trump Ends Health Insurance Marketplace Cost-Sharing Subsidies
ISMP Launches High-Alert Medication Safety Self Assessment Tool