With the 2022 open enrollment phase now in full swing, the Centers for Medicare and Medicaid Services (CMS) have theirs first weekly registration update. The number of enrollments remains high, presumably driven by the further improved subsidies under the American Rescue Plan Act (ARPA). Separately, CMS gave a revised financing methodology for the Basic Health Program (BHP), which will provide Minnesota and New York, the only two states with BHP, an additional $ 850 million.
First weekly open registration report
On November 12, 2021, CMS released its first weekly enrollment snapshot for HealthCare.gov for the open registration period of 2022. A total of 774,000 people in the 33 states using HealthCare.gov have selected a plan. Most of these consumers (640,283 people) renewed their coverage from last year; there were 133,274 new consumers. CMS reports its data weekly – Sunday through Saturday – so this “week one” report covers only six days (November 1st to November 6th).
This appears to be down slightly from the first week of enrollment for the 2021 open enrollment period when the total enrollment was more than 818,000 people. However, the annual reports are not directly comparable for several reasons. Once these differences are factored in, Charles Gaba has Estimates This week, the number of enrollments has increased significantly compared to the previous year.
What are these differences? First, the first week’s snapshot for 2021 included an additional day of enrollment. Second, the 2021 snapshot reflected data from three states– Kentucky, Maine, and New Mexico – all of which moved from HealthCare.gov to their own state marketplace for this year. Enrollment in these states (more than 180,000 people 2021 total) will not be included in the weekly snapshots and could make the total appear lower. Third, this year two states – Missouri and Oklahoma – expanded their Medicaid programs. The individual market generally shrinks after a state expands its Medicaid program as individuals with incomes between 100 percent and 138 percent of the state poverty line migrate from market coverage to the Medicaid program.
Thanks to improved subsidies under the ARPA, CMS continues to promote record-low premiums. This year’s registration cycle builds on registration gains from 1) the 2021 open registration phase, which was the first and only year that HealthCare.gov registration increased under the Trump administration; and 2) the Biden Government’s six-month COVID-19 special enrollment period if, more than 2.8 million people enrolled in insurance coverage nationwide. Together these activities led to record high enrollments of 12.2 million people in market coverage as of August 2021.
A higher enrollment towards the end of the year means a higher enrollment (including automatic re-enrollment) during this year’s open enrollment period. With a wider subscriber base to begin with, the marketplaces are likely to retain more consumers, while attracting new consumers, compared to previous years.
Interest in reporting also remains high. More than 2.7 million people visited HealthCare.gov and the call center volume reached more than 293,500 calls. CuidadoDeSalud.gov had fewer than 100,000 visitors in the first week of the open registration period and there were more than 24,000 calls with Spanish-speaking representatives. In contrast to the reports on the specific registration period, CMS did not publish registration data by gender, race and ethnicity.
The 2022 open registration period runs from November 1, 2021 through January 15, 2022. CMS will post snapshots of the registration every week and expects to release a final report on the open registration (reflecting data from HealthCare.gov and the state) in the spring. based marketplaces).
On November 10, 2021, CMS released Orientation aid on how it would update its methodology for determining federal funding for the BHP to include increased subsidies under the ARPA. All in all, Minnesota is preserved about $ 100 million, more as New York gets about $ 750 million more than expected according to the previous methodology. Federal payments are based on actual enrollment data that has not yet been submitted by the states; CMS notifies states when updated payments have been issued.
The BHP enables states to offer an alternative to market coverage for certain uninsured individuals with incomes between 133 and 200 percent of the federal poverty line. While these individuals are eligible for premium tax credits (PTCs) and co-payment reductions (CSRs) to purchase a marketplace plan, the BHP allows for more affordable coverage and helps minimize switching between Medicaid and private insurance.
To fund the BHP, CMS makes payments to a state equal to 95 percent of the PTCs and CSRs that eligible BHP applicants would have received had they signed up for a qualified health plan through the marketplace. CMS publishes its methodology for these calculations every year. Since the formula for the BHP is based on PTCs and CSRs, the amounts owed to states under the BHP will be higher under the ARPA. The guide explains how the methodology will change for 2020 and 2021 due to the new law.
First, CMS will consider the lower “Applicable Percentage” of ARPA for PTC Eligible Participants. The new applicable percentages range from 0 to 8.5 percent, depending on the household income of the enrolled. The federal government is thus contributing more to the premium costs for eligible enrolled persons, which increases the contribution of the federal states with the BHP.
Second, CMS updated the reconciliation factors for revenue for both 2020 and 2021, albeit for different reasons. For 2020, CMS has adjusted the methodology to reflect the temporary suspension of the pre-PTC voting requirement for the 2020 tax year. While BHP members do not have to reconcile any benefit receipts, the factor for 2020 is set at 101.53 percent.
For 2021, the earnings adjustment factor will be adjusted to reflect the ARPA provision, which will allow those who received or approved unemployment benefits in 2021 to qualify for maximum PTCs and CSRs. Again, this increases the amount of PTC that BHP applicants would have received had they signed up for market coverage, thus increasing the amount that states receive. For 2021 the factor will be 100.61 percent.
Beyond the Methodology: FAQs for States
The guide also includes five questions and answers for states clarifying other ARPA implications for the BHP. For example, BHP members cannot be asked to pay monthly premiums that are higher than the market. This means that Minnesota and New York will need to adjust their BHP awards (if necessary) to match the applicable percentages included in the ARPA.
As a result, states cannot charge monthly bonuses to BHP members whose household income is below 150 percent of the state poverty line. Similar adjustments need to be made for those whose incomes are 150 to 200 percent of the federal poverty line. If a state levied premiums that did not meet this requirement (ie the BHP premiums were too high), the premiums must be reimbursed to low-income students. This applies to the entire calendar year 2021 and includes those who received unemployment benefits in 2021.
States must also retrospectively enroll certain individuals whose income was below 150 percent of the federal poverty line who were eligible but not enrolled for not paying their original premium. According to ARPA, you do not have an initial premium and must therefore be enrolled retrospectively. CMS urges states to ensure that all unpaid claims are covered and reprocessed.