Update: In another ACA development, the IRS has just clarified that an immigrant present in the United States under the Deferred Action for Childhood Arrivals (DACA) program is not considered lawfully present, and is thus eligible for the exemption from the individual responsibility requirement that applies to individuals not lawfully present in the United States. It has long been clear that DACA program immigrants are not eligible for Medicaid and CHIP.
Original post: On March 10, 2015, the HHS Assistant Secretary for Planning and Evaluation (ASPE) released the Health Insurance Marketplaces 2015 Open Enrollment Period March Enrollment Report. The report covers open enrollment activity through February 22, 2015; it contains a wealth of data on 2015 marketplace enrollment, including for the first time enrollee income data that provides some useful insights (discussed in more detail below).
The headlines of the report are old news. Nearly 11.7 million Americans selected or were automatically enrolled in health plans through the marketplaces during the 2015 open enrollment period, including 8.84 million through the exchanges that use healthcare.gov. Of these, 4.6 million were new consumers, 2.2 million actively reenrolled , and nearly 2 million were automatically reenrolled. Nearly 2.85 million people selected plans or were automatically enrolled through state exchanges that used their own marketplace platforms.
About 87 percent of those who enrolled through Healthcare.gov qualified for advance premium tax credits, which averaged $263 per person per month and covered about 72 percent of the gross premium of individuals who qualified, reducing their net premium to a net of $101 per month.
Of the 2.2 million active reenrollees, 1.2 million, or 29 percent, switched plans. This represents an extraordinary level of consumerism. In Medicare Part D about 13 percent of enrollees switch plans each year, as do 12 percent of active enrollees in the Federal Employees Health Benefit Program and 7.5 percent of enrollees in employer plans.
The ASPE Report gives us demographic information for the entire 2015 open enrollment period. Compared to 2014, new consumers during the 2015 open enrollment period were slightly more likely to be male (47 percent 2015, 45 percent 2014); and to be age 34 or under (40 percent 2015, 35 percent 2014). They were slightly more likely to identify as Latino and slightly less likely to identify as African-American.
The most interesting aspect of the report, however, is that it the first ASPE report to include income data on enrollees. One of the biggest unanswered questions about marketplace enrollment has been how many individuals are receiving cost-sharing reduction payments. To receive such payments, an individual must enroll in a silver plan, receive premium tax credits, and have a modified adjusted gross household income of 250 percent of poverty or less (although cost-sharing reduction payments do not become significant until an individual’s MAGI is 200 percent of poverty or less).
For the 2015 open enrollment period, 80 percent of households enrolled in federally facilitated marketplaces had incomes of 250 percent of poverty or less and 65 percent had incomes at or below 200 percent. In states that have not implemented the Medicaid expansion, 50 percent of enrollees had incomes at or below 150 percent of poverty and 23 percent between 150 and 200 percent. In expansion states, 24 percent of enrollees were at or below 150 percent of poverty and 32 percent between 150 and 200 percent of poverty. Of individuals enrolled through healthcare.gov, 87 percent received financial assistance (including presumably virtually everyone below 250 percent of poverty), and 74 percent of those who received financial assistance chose silver plans.
Presumably, therefore, well over half of individuals enrolled through healthcare.gov are receiving cost-sharing reduction payments, perhaps as many as two thirds in non-expansion states. Cost-sharing reduction payments increase the actuarial value of coverage to 94 percent for individuals with MAGI under 150 percent of poverty and to 87 percent for those with incomes between 150 and 200 percent of poverty. Maximum out-of-pocket limits are also reduced sharply for those eligible for cost-sharing reduction payments—by about 2/3 for individuals with incomes below 200 percent of poverty.
The import of this is that although much has been made of high deductibles, coinsurance, and co-payments under marketplace plans, a significant share of those who have enrolled in these plans are paying cost-sharing at much lower levels. This may explain why surveys are finding an increase in the affordability of healthcare under the ACA despite high cost-sharing for silver and bronze plans. For these Americans, not only health insurance, but also health care is affordable because of the Affordable Care Act.
Eligibility For Special Enrollment Period For Those Subject To 2014 Penalty For Lack Of Coverage
One other item should be noted. CMS has clarified eligibility for the new special enrollment period from March 15 through April 30 for individuals who were unaware of the individual responsibility penalty, are subject to it for 2014, and are otherwise not enrolled in minimum essential coverage for 2015. Specifically, a person can take advantage of the special enrollment period even if he or she owes the individual responsibility penalty for only part of 2014. Also, a person is not required to have actually filed his or her taxes for 2014 and paid the fee, but need merely be subject to the penalty.