Health insurers, public and private exchange programs, and traditional agents and brokers today started the first Affordable Care Act (ACA) individual major medical open enrollment period that will begin under the administration of President Donald Trump.
The open enrollment period — the time when people can buy coverage for 2018 without showing they have what regulators believe to be a good excuse for shopping for coverage — started today throughout the country.
A New Schedule
For 2017 coverage, the open enrollment period lasted from Nov. 1, 2016, to Jan. 31, 2017.
For 2018 coverage, in states that use the HealthCare.gov ACA exchange enrollment and administration system, the Trump administration has scheduled the open enrollment period to end Dec. 15.
(Related: 5 Agent Jabs at a Draft ACA Date Change)
That schedule means that much of the HealthCare.gov 2018 individual major medical open enrollment period will overlap with the Medicare plan annual election period, which runs from Oct. 15 to Dec. 7.
Many states that run their own state-based exchange programs say they will give their residents until Jan. 31, 2018, to sign up for 2018 coverage.
A Shield Against 'Free Riders'
The ACA drafters in Congress eliminated many of the traditional defenses, such as medical underwriting and benefits limits, that health insurers once used to protect themselves against claim risk. Most of those changes applied to new major medical coverage that took effect on or after January 2014.
Insurers feared that the new ACA rules would encourage many younger, healthier consumers to act as "free riders," and to pay for coverage only when they thought they would need expensive health care.
To reduce the risk that consumers would see the new underwriting rules as an invitation to pay for coverage only when they arrived at the hospital door, regulators, ACA exchange programs and insurers developed the open enrollment system.
The open enrollment systems lets eligible people buy coverage on a guaranteed-issue basis during an annual open enrollment period.
At other times of the year, people who want major medical coverage can show they qualify for a "special enrollment period" (SEP) because they have moved, lost employer-sponsored health coverage, had a child, or met some other conditions on the government's list of conditions that make health insurance shoppers eligible for SEPs.
The 2018 open enrollment period is the fifth conducted under the ACA open enrollment period rules.
No Open Enrollment Calendar
The ACA drafters excluded some types of coverage from the effects of most or all ACA major medical coverage rules.
Because of those exclusion provisions, the ACA underwriting rules, and the ACA open enrollment period system, do not apply to short-term health insurance or to a variety of "gap-filler" products, such as hospital indemnity insurance, critical illness insurance or accident insurance.
Some observers have emphasized that insurer concerns about past open enrollment periods, and, possibly, Trump administration actions and rule changes have reduced the number of individual major medical plans available in many counties, increased the full price and reduced the number of issuers willing to pay sales commissions to agents and brokers.
The Centers for Medicare and Medicaid Services (CMS), the arm of the U.S. Department of Health and Human Services that runs HealthCare.gov and oversees all states' ACA public exchange programs, says it expects the average full monthly premium for the ACA exchange system's main benchmark plan, the "second-lowest cost silver plan," will increase 37% in 2018.
The cost of the average plan for the average, unsubsidized 27-year-old could be $411 month in 2018, up from $300 per month this year.
Other observers, including analysts at the Congressional Budget Office, say that the average change in the price of the average plan has little to do with what consumers really pay for coverage, because most exchange users qualify for premium subsidies that will eliminate the effects of the change. An actuarial firm told managers of the state-based exchange in Colorado that many enrollees there who shop actively for coverage will pay less out of their own pockets for 2018 coverage than they are paying for coverage this year.
Another question is how 2018 exchange coverage might be sold.
CMS has slashed funding for nonprofit HealthCare.gov exchange navigators and other nonprofit exchange helpers this year, and it says it will shut HealthCare.gov down for maintenance from right after midnight on Sunday to noon on Sunday throughout the open enrollment period.
It's not clear how many issuers will pay sales commissions to application fees to agents and brokers this year.
But CMS has tried to make it easier for web brokers, such as eHealth Inc., to sell subsidized coverage directly to consumers through their own websites, rather than making the web brokers hand off the consumers to HealthCare.gov.
Public exchange programs do not actually create health insurance, and they mostly sell plans from private carriers, not plans from government programs.
During the open enrollment period for 2017, the exchange system helped a total of 12.2 million people sign up for 2017 coverage. HealthCare.gov alone helped 9.2 million people in 39 states sign up for 2017 coverage.
HealthCare.gov agent certification activity could be an early 2018 open enrollment period performance indicator. As of Monday, HealthCare.gov had certified about 43,000 agents and brokers to help consumers sign up for exchange coverage for 2018. A year earlier, the exchange had certified about 75,000 exchange agents for the open enrollment period for 2017 coverage.
The 2018 HealthCare.gov exchange count is 43% lower than the 2017 count.
If 2018 ACA public exchange plan enrollment is 43% lower than the 2017 enrollment level, then the exchange system could end up helping about 7 million people get covered for 2018.
—Read New HealthCare.gov Flexibility Could Ease 2018 Pain: Exec on ThinkAdvisor.