With the Patient Protection and Affordable Care Act’s (ACA’s) ninth open enrollment period (OEP) set to launch in less than a month, the ACA Marketplaces are seeing record enrollment numbers with more generous subsidies, new carrier competition, and a relatively stable rating environment. At the same time, there is uncertainty with the trajectory of the COVID-19 pandemic and medical costs trending upward as the economy recovers, albeit at an uneven pace. These trends have made for a challenging rate review process in the 47 states plus the District of Columbia (D.C.) that conduct their own ACA rate reviews of carrier-proposed rates using federal review standards. State announcements of 2022 rates have trickled out at a slower pace than in prior years, and it is likely that many states will not publish their approved rates until the beginning of open enrollment. As always, state rate results vary widely and, even within states, there often are substantial variations among carriers and across different regions in geographically diverse states. With these caveats, this expert perspective highlights some observations about the factors that are impacting rate changes this year and the kind of variations that exist among states.
Assessment of Current Coverage Programs and Future Options
Manatt Health Solutions
This template, prepared by Manatt Health Solutions, is intended to assist states in evaluating the options with respect to transitioning certain Medicaid and state-funded populations and programs into a post-ACA coverage environment with Medicaid eligibility for non-disabled adults under age 65 (potentially) expanded to 133% of the FPL and tax credits and cost sharing reductions available to individuals between 133% and 400% of the FPL (or between 100% and 400% in a non-expansion state). The template suggests populations and programs that may be eligible to transition into the new adult Medicaid group or the Exchange, but each state will want to create a state-specific list of programs. With respect to each of the populations or programs eligible to transition, the template suggests nine factors for consideration, ranging from the difference in covered benefits and consumer cost-sharing to the impact on state financing and the administrative complexity of maintaining or eliminating the program. Finally, the template rolls up the considerations and lays out the possible decisions: maintain the program for some or all consumers; transition some or all consumers to the Medicaid new adult group; or, transition some or all consumers to the Exchange.
This template was rolled out by Manatt at the “Introduction to the State Health Reform Assistance Network” session at the 25th National Academy for State Health Policy Meeting on October 15, 2012. The slides from this presentation can be accessed here.