Broker blog from Delta Dental

Tag: policy

Policy pops: Health care exchanges — 2019 enrollment results

3‑minute read

Join our guest blogger, Devin McBrayer, as she reviews the outcomes of the 2019 open enrollment period for health care exchanges. Devin is a Legislative and Policy Analyst based in Sacramento, California.

The open enrollment period to purchase Affordable Care Act (ACA)-compliant individual health insurance coverage off the health insurance exchanges for 2019 has come to an end. Sign-ups were off to a slow start at the beginning of the enrollment period, leaving many experts fearful that ACA plans would experience a significant decrease in enrollment. However, total enrollment only decreased by about 3.8% nationwide on Healthcare.gov, much of this due to a 15% reduction in new sign-ups. 

While the total enrollment drop in individual health insurance plans on the exchange may have been less drastic than expected, it is still worth exploring why new enrollment decreased considerably and why year-to-year enrollment continues to decline. Several 2018 policy changes, combined with a growing economy, could help explain the decrease in enrollment in ACA plans for the 2019 plan year. 

Are policy changes to blame?

In 2018, Congress reduced the tax penalty for not having an ACA-compliant health insurance plan to zero, effectively eliminating it. The federal government also shortened the open enrollment period and reduced marketing for open enrollment. Simultaneously, the federal government passed several rules that expanded the availability of cheaper and less comprehensive insurance plans such as short-term limited duration plans. No tax penalty for lack of coverage, combined with a shorter sign-up period and more plan options outside the exchanges, may help explain the enrollment decrease.

The impact of the economy

Another possible explanation for the drop in enrollment could be attributed to an improving economy. When open enrollment started on November 1, 2018, 2 million more jobs were added to the economy than were added at the same time in 2017. As more people head back to work, it’s possible that they’re gaining access to employer-sponsored health insurance, eliminating the need to renew their ACA plan. 

What does this mean for dental?

Any loss in enrollment for medical coverage also means less people enrolled in dental coverage on the exchange. (As a reminder, dental coverage is an essential health benefit for children but not for adults.) 

In the exchanges, dental coverage is included in some health plans or consumers can get a stand-alone dental plan and pay a separate premium. However, there is no way for consumers to purchase a stand-alone dental plan without also purchasing a medical plan on the health care exchange. Pushing for states and the federal government to allow for the independent purchase of stand-alone dental plans on state and federal health insurance exchanges is a top priority for the Public & Government Affairs team at Delta Dental.

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Policy pops: The long and short of short-term health plans

3‑minute read

Join our guest blogger, Stephanie Berry, as she answers frequently asked questions about short-term limited duration health insurance plans (STLD). Stephanie is a Senior Legislative and Policy Analyst based in Rancho Cordova, California.

On October 2, the U.S. Department of Health and Human Services (HHS) put new rules into effect lengthening the maximum duration for short-term limited duration health insurance (STLD). Prior to the enactment of the Affordable Care Act (ACA), STLD plans were prevalent in the individual market for people who experienced temporary gaps in health coverage, such as losing or changing a job. Unlike “limited benefit” policies, such as cancer-only or hospital-only policies, STLD plans were considered akin to comprehensive medical plans, only differing in their limited term, previously 90 or less days. The new HHS regulations increase the duration of STLD plans, potentially making them more appealing to certain demographics, particularly younger, healthier consumers.

FAQ:

Q: How long can these new STLD plans last?

A: The new rules state that a short-term plan can last up to a year (364 days), and consumers will be able to renew that plan for a maximum of two additional years (up to 36 months). This is a change from the federal rules, which previously limited STLD plans to three months. Individual health plans have been guaranteed renewable since 1996, whereas STLD plans previously terminated at the end of the contract, meaning that a change in health status could cause policyholders to be dropped from coverage.

Q: Do STLD plans have to follow the same ACA rules regarding medical underwriting, pre-existing condition exclusions, etc.?

A: No. The ACA exempted STLD plans from market rules. As a result, the following are permissible under STLD plans:

  • Medical underwriting: Applicants can be excluded or charged higher premiums based on health status, gender, or age
  • Excluding coverage for pre-existing conditions
  • No coverage for essential health benefits that ACA-compliant plans must cover, such as pregnancy, prescription drugs, or mental health care
  • Lifetime or annual limits
  • No limit to out-of-pocket expenses

Q: Can dental be offered as an STLD product?

A: STLD products are meant to compete with major medical plans, and, as a result, there is not a clear role for stand-alone dental carriers in the STLD space.

Q: How do STLD plans differ from Association Health Plans?

A: Think of Association Health Plans as a way for members of associations to band together to purchase large group health insurance. As a result, an AHP could choose an STLD plan as the health insurance plan it offers to its members.

Q: What role do states play in regulating STLD products?

A: States can take action to comply with the new STLD regulations or implement their own restrictions and guidelines, many of which are already enshrined in state law. Brokers should reach out to state departments to understand any additional state requirements. Here are a few examples on how states are reacting to the new STLD regulations:

  • Four states currently prohibit STLD plans, including Massachusetts, New Jersey, New York and California (SB 910 in California was signed by the governor in September). Relatedly, Hawaii enacted a law this year (HB 1520) that bars residents from enrolling in STLD policies if they are otherwise eligible to purchase coverage from the federal health insurance marketplace during an open or special enrollment period. It also limits the duration of an STLD policy to less than 91 days.
  • States can – and have – adopted shorter maximum durations of an STLD policy. For instance, the South Carolina Department of Insurance has restricted STLD policies to 11 months or less, and limits renewals to a total of 33 months or less coverage. (This is intended to distinguish STLD policies from ACA-compliant policies.) Michigan, by contrast, limits STLD policies to six months or less out of any 365-day period.
  • States can impose requirements on disclosure and marketing. The Maine Bureau of Insurance issued a bulletin stating that when offering an STLD policy, a carrier or broker must provide clear language that the policy does not offer protections from pre-existing condition exclusions or guaranteed renewability. Both Nebraska and Iowa require a “free-look” period, whereby the newly-insured can cancel the policy within a set timeframe.
  • States can require STLD products to cover essential health benefits (EHBs) or other ACA-market protections. The Connecticut Insurance Department issued a bulletin to clarify that STLD plans must cover EHBs, and that any renewable STLD plan or any STLD that has a duration of six months or longer is prohibited from excluding coverage for pre-existing conditions. Maine law requires STLD plans to cover preventive health services and bars dollar limits on coverage.

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Policy pops: Midterm elections’ impact on Medicaid (and dental) expansion

3‑minute read

Join our guest blogger, Devin McBrayer, as she explores the role of Medicaid expansion in the midterm elections and the potential impact on low-income adults’ access to dental benefits. Devin is a legislative and policy analyst based in Sacramento, California.

Midterm elections are just around the corner on November 6, and the results of the election could change the future of Medicaid in several states. Medicaid expansion is an important platform issue for some contested governors’ races as well as the subject of several ballot initiatives across the country. If more states expand Medicaid coverage for adults through the Affordable Care Act (ACA), dental coverage for low-income adults could also grow.

Currently, 33 states, plus Washington D.C., have opted to expand Medicaid, and 14 states have chosen not to do so. Three states, Idaho, Nebraska and Utah, will vote on Medicaid expansion for the first time this Election Day. If these states vote to expand their Medicaid programs, an additional 300,000 low-income Americans would be eligible for coverage. Montana also has a ballot initiative to extend their temporary expansion that covers 100,000 people in the state. Unless Montana voters approve the ballot initiative, the temporary expansion of Medicaid will end in 2019.

Several hotly-contested races for governor also feature Medicaid expansion as a central issue for candidates. Florida, Georgia, Kansas and Wisconsin all have Democratic gubernatorial candidates interested in expanding Medicaid if elected. Medicaid expansion could open the doors to providing more extensive dental benefits for those states’ adult populations in the future. Florida and Georgia’s current state Medicaid programs, in particular, offer emergency-only adult dental benefits, which are most often limited to pain relief under very specific situations.

Most states offer a limited dental benefit to their adult Medicaid population, but since adult dental is not a required benefit and the state must pay the entire cost of providing the benefit, fewer than half of states offer an extensive adult dental benefit. In FY 2018, 19 Medicaid expansion states chose to enhance the covered benefits in their Medicaid program, and three of those states, Arizona, California and Utah, chose specifically to enhance the dental benefit or access to dental services.

Along with the impact of elections on Medicaid expansion, it’s important to have an eye on the economic conditions. States that expanded their Medicaid programs in 2014–2016 received a 100% funding match from the federal government for newly eligible Medicaid enrollees. However, this federal match has begun to phase down and by 2020 the match will drop to 90%, which will force states to finance a greater share of the costs of Medicaid expansion. Delta Dental will continue to monitor these important elections and other trends that could have big impacts on low-income adults’ access to dental benefits across the country.

For more thought leadership from Delta Dental, subscribe to Insider Update, our newsletter for brokers, agents and consultants.

If you’re a benefits decision maker, administrator or HR professional, subscribe to our group newsletter, Word of Mouth.

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