The non-group market has functioned as a remainder market, a
market of last resort for those who don’t qualify for government and employer medical
benefit plans that cover about 90 percent of those with coverage. Non group
plan issuers have thus labored with comparatively lower economic clout when it
comes to negotiating the price of medical care with its providers, additionally
hindered by high turnover among plan members that might be expected in a market
of last resort.
Historically, that has meant relatively higher premiums and
cost sharing that makes non-group particularly vulnerable to adverse selection
and its dreaded “death spiral.” The market entered this troubled state starting
in the early 2000s as premiums rose and threatened to circle the drain if the
adverse selection trend wasn’t quickly reversed. The Patient Protection and
Affordable Care Act came to the rescue with a mix of incentives and disincentives
to preserve the viability of the non-group market with state health benefit exchanges,
a ban on medical underwriting like that employed by life insurers, modified community-based
rating, and advance premium tax credit (APTC) subsidies. The latter two reforms
however only partially succeeded. Modified community-based rating allowed age
to be used in setting premiums, though narrowing the differential between younger
and older people. The tax credit subsidies didn’t apply to the entire market, but
only for households earning less than four times the federal poverty limit.
That exposed a portion of the non-group market to market failure, particularly the
demographic aged 50-64 likelier to be in their high earning years and who also
face higher premiums by virtue of their years.
The U.S. Centers
for Medicare & Medicaid Services (CMS) has issued a report Trends in
Subsidized and Unsubsidized Enrollment Report. According to CMS, the
most recent year of enrollment data shows average monthly enrollment across the
entire individual market decreased by seven percent nationally between 2017 and
2018 at the same time premiums increased by 26 percent. It attributed the drop entirely
to those ineligible for APTC subsidies, noting unsubsidized enrollment declined
by 24 percent, compared to a four percent increase in APTC subsidized
enrollment.
“The report shows
that people who do not qualify for APTC continue to be priced out of the market,”
CMS stated in a news
release today. CMS reported an enrollment
drop of 1.3 million unsubsidized people in 2017 and another 1.2 million
unsubsidized people leaving the market in 2018. The declines among unsubsidized
enrollees coincided with increases in average monthly premiums of 21 percent in
2017 and 26 percent in 2018, according to CMS.
“As President Trump predicted, people are fleeing the individual market. Obamacare is failing the American people, and the ongoing exodus of the unsubsidized population from the market proves that Obamacare’s sky-high premiums are unaffordable,” said CMS Administrator Seema Verma.
“Fleeing the market” or “priced out.” Whatever the preferred
terminology, the economic upshot is the same: market failure. When any product
or service is priced above a level that’s affordable by its intended market,
there can be no sustainable market unless prices fall or incomes or subsidies
rise — or some combination thereof. The federal tax code allows self employed taxpayers
to deduct premiums for non-group plans. That provides some benefit, but doesn’t
help with affordability.
California with its larger non-group population is
attempting to prop up the weak plank of insufficient subsidies by expanding eligibility
limits to households earning 600 percent of federal poverty levels starting in plan
year 2020, supported by state income tax penalties levied on those without some
form of commercial or government coverage. If it has a meaningful impact on
affordability in the challenging older subset of the non-group market, federal candidates
in the 2020 election cycle who favor keeping the Affordable Care Act’s reforms
of the non-group market intact and/or boosting tax credit subsidies won’t be
able to point to the state’s success since the results won’t be in until after
the election.
Ultimately, market failure in the older age cohort of the
non-group segment may lead federal policymakers to conclude it makes better
sense to move forward with proposals to bring that population into Medicare via
an early “buy in” option rather than tie themselves in knots trying to create a
viable market for a relatively small number of Americans.