An arm of the U.S. Department of Health and Human Services (HHS) has just come out with a new commentary on how many U.S. residents might get public exchange plan coverage in 2015.
The second annual Patient Protection and Affordable Care Act (PPACA) open enrollment period is set to start Saturday and end Feb. 15, 2015.
Analysts at the HHS Office of the Assistant Secretary for Planning and Evaluation (ASPE) have suggested that the country could end up with 9 million to 9.9 million paid exchange qualified health plan (QHP) enrollees in 2015. Originally, analysts at the Congressional Budget Office (CBO) suggested that the exchange QHPs might have 13 million enrollees in 2015.
QHP enrollment will probably be lower than the CBO predicted in the coming year because employers and purchasers of individual exchange are moving toward the public exchange system more slowly than expected, the ASPE analysts say. They point out that the CBO analysts assumed the PPACA exchanges would take about three years to expand to their full size. In the real world, the ASPE analysts say, big new health programs seem to take about five years to ramp up to their full size.
Edmund Haislmaier, a senior research fellow at the Heritage Foundation, said the CBO numbers were soft to begin with. “The new projections from HHS are still optimistic but more realistic,” Haislmaier said.
Rep. Darrell Issa, R-Calif., chairman of the House Oversight & Government Reform Committee, said in a statement that he believes HHS is just trying to move the goal posts to lower expectations.
For insurance agents and brokers, knowing just how many consumers will get QHPs from the exchanges, PPACA-compliant plans off-exchange, or PPACA plan alternatives off-exchange could be helpful.
If you’re a producer, should you focus mainly on offering PPACA exchange assistance services and gap-filler products for exchange users; off-exchange PPACA plans; or products meant to help consumers with old, grandfathered and “grandmothered” PPACA-free major medical plans keep those PPACA-free plans as long as possible?
Or, will PPACA plans of all kinds be such a nightmare that you need to figure out how to persuade consumers to swallow hard, pay the PPACA penalty to be imposed on the uninsured or underinsured, and buy a medically underwritten short-term health insurance policy with a flexible network and a modest deductible rather than a policy that offers unlimited benefits for liver transplants but little help with paying to fix broken arms?
So, can you use the HHS crystal ball to shape your own marketing and resource planning?
For ideas about why relying on that crystal ball might not be a great choice, read on.
1. HHS has motives to come up with predictions that are on the low side.
HHS analysts themselves actually estimated in mid-2013 that the exchange system would attract only 4.3 million enrollees, and they did not think at the time to bother to try to distinguish between consumers had signed up for coverage and those who had paid.
officials then spent months explaining why they hoped the PPACA exchange system still could possibly overcome enrollment system glitches well enough to attract the 7 million enrollees that CBO analysts had projected the exchanges might attract.
Once HHS officials found, in April, that more than 7 million people had chosen exchange QHPs, they then spent months dealing with critics who asked whether the consumers had actually paid for their coverage. Once HHS officials reported that the vast major of the consumers who had signed up for coverage had paid for coverage, they then had to deal with questions whether all of the paid enrollees were still enrolled, or whether some had dropped out and let the number fall to less than 7 million — even though, again, HHS itself had not created the 7 million figure.
Another reason for HHS to keep volume estimates on the low side is that a somewhat lower enrollment level might reduce the value of official exchange regulation and exchange paperwork burden estimates.