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PPACA Enrollment Period 2015: The curtain (really) falls

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The states with exchanges will be ending their tax season special enrollment period (SEP) at 11:59 p.m. EDT today.

Most of the states with locally run exchanges that are offering tax season SEPs are also ending their SEPs today.

The deadline means that, around 11:59 p.m. EDT, the Patient Protection and Affordable Care Act (PPACA) public exchange system will have about all of the qualified health plan (QHP) enrollees they are going to get through the open enrollment period and broad enrollment period extensions.

See also: Plan maker: PPACA enrollment calendar flunks buzz test 

The official major medical enrollment period for 2015 started Nov. 15 and was supposed to end March 15 in most of the country. Regulators added the tax season SEP to help consumers who say they first learned about the new penalty that PPACA imposes on many people who lack minimum essential coverage (MEC) when they filed their income taxes for 2014.

Charles Gaba, the editor of the major medical enrollment blog, has estimated that the public exchanges have about 12.3 million QHP enrollees, or people who have selected QHPs and still have time to make their first premium payment.

The total includes 9.4 million HealthCare QHP enrollees and about 3 million state-based exchange QHP enrollees.

Gaba has suggested that consumers may have also bought about 8.6 million PPACA-compliant policies outside the exchange system, and that the PPACA Small Business Health Options Program (SHOP) exchange programs may be providing coverage for about 330,000 people.

So, what really happened?

Many of the players are still vague about what exactly it was that they saw. 

For a look at some of the latest reports, read on. 

Guy in a suit jumping over hurdles

1. Public exchange plan selection activity met the low goal HHS set, but it fell short of the original CBO enrollment forecast.

The Centers for Medicare & Medicaid Services (CMS), the arm of the U.S. Department of Health and Human Services (HHS) in charge of the PPACA system, originally estimated in a paperwork review notice that the exchanges would get only about 4.3 million applications for 2014 QHP coverage, but the Congressional Budget Office (CBO) suggested the exchanges would get 7 million enrollees.

The exchanges seem to have ended up with about 8 million plan selectors, and about 7 million who actually paid for coverage.

This year, CMS and HHS officials tried to lower expectations by saying they would be happy to attract 9 million to 9.9 million paid QHP enrollees for 2015.

The CBO originally estimated the exchanges would have 13 million enrollees for 2015. Some insurers and exchange managers were hoping that smoothly functioning exchange systems, and evidence from 2014 that QHPs worked, would help the public exchange system reach the 13 million threshold.

But the exchanges seem to have had less marketing funding this time around, the second open enrollment season was shorter, and HHS had to contend with several U.S. cases of Ebola just as it was preparing to start the enrollment period.

Some QHP issuers have said they were happy with 2015 sales, but an executive at Anthem Inc. (NYSE:ANTM) said Wednesday that sales were somewhat lower than expected.

See also: Avalere: users are sticky

More on this topic

Man facing a blank wall

2. Rating agencies seem to be struggling to find a way to describe how the new PPACA system did, or did not, cause Assurant Inc. (NYSE:AIZ) to back away from the health insurance market.

Moody’s Investors Service affirmed the parent company’s senior debt rating at Baa2, and cut the insurance financial strength rating of Assurant Health to Baa3, from Baa2.

Assurant implied that changes in PPACA rules had hurt results.

Moody’s said of the effects of PPACA on Assurant Health only that the companies’ stand-alone credit profiles “take into account widening net losses on individual medical policies under the Affordable Care Act.”

Standard & Poor’s Ratings Service affirmed its BBB plus long-term counterparty credit rating on the parent company and its A minus rating on the insurance companies that make up Assurant Health, but it changed the outlook on Assurant Health to negative, from stable.

S&P did not mention PPACA in its comment on the Assurant Health news. 


3. A watchdog agency sees signs that the IRS has little ability to go after employers that fail to make PPACA-related payments.

PPACA requires the Internal Revenue Service (IRS) to work with HHS to enforce compliance with new tax, penalty and assessment provisions. 

One of the first PPACA revenue-raising provision to take effect has been a fee that’s supposed to fund the operations of the Patient-Centered Outcomes Research Institute (PCORI), a federal agency that’s supposed to commission studies comparing the effectiveness of various medical treatments.

Plans and insurers were supposed to pay $1 per covered life in July 2013, and $2 per life for plan years ending after Oct. 1, 2013.

Officials at the Treasury Inspector General for Tax Administration (TIGTA), an agency that keeps tabs on the IRS, says the IRS is having trouble administering the PCORI fee requirement.

Insurers and plan sponsors filed 72,035 PCORI fee forms for the 2012 tax year, and paid $114 million through the forms, TIGTA officials say.

When TIGTA officials themselves looked at the data from outside sources, they found evidence that 25 of the 391 health policy issuers that filed supplemental health care exhibits with state insurance regulators had failed to file PCORI tax forms. Those issuers covered about 1.5 million people, or about 1 percent of the lives included in the supplemental health care exhibit filings.

TIGTA officials also estimated that sponsors of self-insured health plans with about 1.8 million enrollees had failed to file PCORI tax forms.

Corporate office

4. Some carriers just didn’t talk about PPACA all that much, when they could avoid it.

Cigna Corp. (NYSE:CI), for example, spoke only briefly about PPACA and the public exchange system when it announced its first-quarter earnings.

The company is reporting $531 million in net income for the first quarter on $9.5 billion in revenue, compared with $528 million in net income on $8.5 billion in revenue for the first quarter of 2014.

Cigna says in its quarterly financial filing that it hopes to collect $30 million in PPACA “risk mitigation programs” money as of the first quarter of 2015. A year earlier, it posted a $10 million risk mitigation programs receivable.

During a conference call with securities analysts, company executives said that most of the receivable would be coming from the PPACA reinsurance program. They said of exchange plan financial performance that they knew going in that the plans would probably not generate much revenue or income early on.

This year, the loss in the business is probably lower than it was in 2014, and the company is hoping performance will improve in 2016, executives said.

David Cordani, the company’s president, talked more about private exchanges. The company has seen “relatively modest adoption,” but that the private exchange system is also in its early stages. Many adopters are using health accounts or coinsurance requirements to give the enrollees an incentive to hold down the cost of care, he said.