Actuarial Science In A Post Reform World Number 10: YOU MIGHT BE AN ACTUARY IF You hear a joke on Monday and start laughing about on Tuesday! 2 HIPAA ‘97 Key Portability Provisions Category Key Provisions General Provisions Provides consumer rights to coverage when transitioning from: Consumers in Group Market • Guarantees availability of coverage for small employers • Guarantees renewability for both small and large employers • Limits preexisting condition exclusions • Prohibits discrimination in enrollment/premiums based on health status • Requires special enrollment opportunities (e.g., child’s birth) Consumers In Individual Market For HIPAA-eligible consumers seeking to buy individual policy: States’ Role • Preserves states’ authority in regulating health insurance • Allows HIPAA-eligible individuals with no access to group plans and considered medically uninsurable to buy coverage through state high risk pools (if available) 3 • One group health plan to another group health plan • A group health plan to an individual policy • An individual policy to a new group health plan • Guarantees right to purchase individual coverage • Prohibits preexisting conditions exclusions • Guarantees renewal of individual coverage from same issuer (most cases) Utah Group Rate Bands 2.5 2.0 1.5 1.0 0.5 0.0 1 2 3 Average 4 5 6 Lower Band 4 7 8 Upper Band 9 10 Individual Selection Curve $400 $350 $300 $250 $200 $150 $100 $50 $0 1 2 3 4 5 Relativity 6 7 Average 5 8 9 10 Number 9: YOU MIGHT BE AN ACTUARY IF After taking a course in heredity you write a paper providing conclusive proof that if your parents didn’t have children, you probably won’t either! 6 Understanding Health Care Claims Cost 7 If Food Were Health Care trended from 1930 $122.48 $107.90 $110 $90 $102.07 $80.20 $70 $64.17 $50 $30 $43.57 $24.20 $10 8 Source: American Institute for Preventive Medicine Where the Spending Goes Prescription, 14.0% Inpatient, 30.0% Other, 4.0% Physician, 36.0% Outpatient, 16.0% 9 Source: PricewaterhouseCoopers Health Care Trend 2008 Average Medical Expense by Age 400% 350% Relationship to Average Cost 300% 250% 200% 150% 100% 50% 0% Under 25 25 30 35 40 45 50 55 60 65+ Age 10 How are claims distributed through the population? Proportion of Population with Claims less than a given threshold 100.0% 90.0% Proportion of the Population 80.0% 70.0% 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% 0.0% 5.0% 10.0% 20.0% 25.0% 50.0% 75.0% 100.0% 125.0% 175.0% 200.0% 300.0% 500.0%1000.0% Over 1000% Threshold as Percentage of Average Claims 11 How are claims distributed through the population? Proportion of Population vs. Proportion of Claims 100% 94.0% 90% 99.1% 88.7% 81.3% 80% 66.2% 70% % of total claims 97.0% 60% 52.7% 50% 40% 30% 20% 10% 0%0.0% 0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50% 55% 60% 65% 70% 75% 80% 85% 90% 95% 100% % of Population 12 Number 8: YOU MIGHT BE AN ACTUARY IF You would rather be completely wrong than approximately right! 1 3 Congress and the Administration Had Three Major Goals for Health Reform 1 Coverage & Insurance Market Reform Make insurance more accessible and affordable for all individuals 2 Delivery & Payment System Reform Pay for quality instead of volume of care 3 Financing Strategies for Health Reform Find sustainable funding to pay for reform provisions © Avalere Health LLC Page 14 Health Reform Implementation Timeline Health Insurer Annual Fee New High Risk Pools Medicaid Expansion Mandatory Expanded Coverage of Preventive Services Individual and Employer Mandates/Penalties Rescission Limitations Rating Limits and Benefit Requirements No Pre-existing Condition Exclusions for Children under 19 Prohibition of Lifetime Limits Extend Dependent Coverage Grandfathering Requirements 2010 •MLR = Medical Loss Ratio •MA = Medicare Advantage Prohibition of Annual Limits Guaranteed Issue and Renewability MLR Requirement MA Quality Payments Begin MLR Requirements for MA Plans MA Payments Frozen MA RegionallyAdjusted Benchmarks PhaseIn Begins Exchanges Begin Operations 2011 2012 2013 Excise Tax on High Cost Plans Premium and Cost Sharing Subsidies 2014 2015 2016 2017 2018 Rating Limits and Benefit Requirements 2014 Exchanges Begin Operation Adjusted Community Rates 3-1 Age Bands Bronze-Silver-Gold-Platinum Plans 16 Consumer Experience In the New World Gov’t. Economy ACA Implementation Technology Coverage/Eligibility Employer New Rules Better Info Exchange Consumers Expanded Programs Level Playing Field Medicare Medicaid Credits 17 Choices Other (e.g., TANF) Health Plan Choice CBO Projects Law Will Increase Insured Population by 31M in 2016 Expected Sources of Coverage, in Millions of Persons Non-group/ Exchanges Employersponsored insurance Medicare Medicaid/ CHIP Uninsured Source: CBO March 20, 2010 Cost Estimate of the combined effect of H.R. 4872, the Reconciliation Act of 2010, and H.R. 3590, the Patient Protection and Affordable Care Act, as passed by the House March 21, 2010; Medicare Data: CBO’s March 2009 Baseline, March 24, 2009. CHIP=Children’s Health Insurance Program. Predicted 2016 Market Shifts Today 2014 0 56.6 Medicaid 47.8 63.2 Medicare 43.4 55.0 Individual 17.1 0 Small Group 33.6 13 Large Group 121.8 118.1 Military 12.4 12.4 Uninsured 50.6 20 326.7 338.3 HC Reform Exchanges Total 19 Number 7: YOU MIGHT BE AN ACTUARY IF You like to have fun… only when nobody is watching! 2 0 Standards for Exchanges Issue Details Enrollment ACA requires fixed annual enrollment periods: 2014: Oct 1, 2013 – Feb 28, 2014; 2015+: October 15 – December 7 Conditional State Approval States granted additional flexibility to meet the Jan 1, 2013 deadline for certification to avoid federal intervention in creating an exchange Geography / Rating Areas States allowed to establish subsidiary exchanges that cover “geographically” distinct areas with at least one rating area Funding States may assess user fees on participating health plans Navigators versus Agents / Brokers Exchanges must create navigator programs to provide “fair and impartial” information and facilitate enrollment States may decide whether to permit brokers /agents to enroll individuals Plan Participation States decide whether to allow participation by any qualified plan or to use more selective contracting / competitive bidding Rate Increases Exchanges must receive justification of rate increases from plans prior to implementation and post reasons for increase prominently on website Network Adequacy All qualified plans must have adequate provider networks but states will decide on the criteria for measuring network adequacy. Individual Exchanges: Open Issues Issue Open Issue Enrollment • Should coverage begin only at the start of a month or should it occur 2x monthly? Autoassignment • Should HHS require an auto-enrollment process when plans are no longer offered or plans are involved in M&A? SEPs • What triggering event, if any, should enable an individual to change the metallic level of coverage during the year? Rate Changes • How often should plans be allowed to change rates? Annually, quarterly, monthly? Accreditation • How long should issuers have to receive accreditation from the time their QHPs are certified? Network Adequacy • What standards/metrics should Exchanges use evaluate whether QHPs offer provider networks with sufficient access? • Should Exchanges broadly define the types of providers that furnish primary care services (e.g., NPs)? 22 Proposed Governance for Exchanges Federal Requirements Exchange governing bodies may be housed within government agencies or as freestanding nonprofit entities (or a combination of both) At least half of all voting board members must represent consumer interests WV •10-person board in the Department of the Insurance Commissioner • Includes consumer and employer WV representation, plus one plan rep State Government Runs Independent • 5-person independent, quasigovernmental board • Includes appointed members that may not represent health plans or providers CA Number 6: YOU MIGHT BE AN ACTUARY IF You are so dull, the accountants notice! 2 4 SHOP Exchange Standards Issue Details Plan Choice Employers select a benefit tier; employees choose a plan within tier Rate Changes Participating plans can only make changes in a uniform timeframe Must hold rates constant within a plan year Application Process States must accept a single application form from employers Must also accept single employee applications Enrollment States must establish a uniform enrollment timeline and process for all plans and employers Exchanges must allow rolling enrollment for small groups SHOP Exchanges: Open Issues Issue Open Issue Employee Choice • Should employers be allowed to limit employee choice to one plan or to select from multiple tiers? Employer Size & Min. Participation • Should HHS institute standards for calculating employer size? • Should there be minimum standards for employee participation? Premium Aggregation • Should SHOP Exchanges be required to provide employers with a single monthly bill and send premiums to issuers or allow more Exchange flexibility? Subsidiary Exchanges • Should subsidiary exchanges for the individual and group market be geographically identical? 26 SHOP Exchange Options Federal Requirements States integrate SHOP with individual exchange or administer them separately Includes groups up to 100 employees—states may include larger employers or limit to <50 Exchanges must offer employee choice—states and employers may limit plan options or offer extra flexibility to choose between tiers • Separate exchanges; SHOP limited to groups <50 WVrequirements for employee • Minimum choice Limited Market, Less Flexibility Large Market, Broad Flexibility • Integrated exchanges; SHOP eligibility expanded to large groups • Broad employee choice options for employers Number 5: YOU MIGHT BE AN ACTUARY IF When asked by a beautiful woman for your phone number you give her the number, plus or minus 10%! 2 8 Changes Resulting From Adjusted Community Rating 29 Impact of Reform on Rating Post-Reform Allowable Rating Relationship vs. Actual Cost Relationship 400% Relationship to Average Cost 350% 300% 250% Actual Cost Relationship 200% 150% 100% Post Reform Allowable Rating Relationship 50% 0% Under 25 25 30 35 40 45 50 55 60 65+ Age 30 Impact of Underwriting Post-Reform Allowable Rating Relationship vs. Actual Cost Relationship 400% Relationship to Average Cost 350% 300% Actual Cost Relationship 250% 200% Post reform Allowable Rating Relationship 150% 100% 50% 0% Under 25 25 30 35 40 45 Age 50 55 60 65+ 31 Number 4: YOU MIGHT BE AN ACTUARY IF • You concluded you’re popular because… …you talked to someone. The Risk and Cost of Adverse Risk 33 In the face of new health reform restrictions, expect more small employers to opt for self-funded health benefits—so concludes a report this week from Indianapolis-based United Benefit Advisors LLC. J.K. Wall March 23, 2011 UBA, which links a network of employer-benefits agencies across the country, found in 2010 surveys that roughly 12 percent of employers with fewer than 200 workers have self-funded plans, but more are showing interest in them since the passage of the health reform law a year ago. 34 Analysis from Aetna’s earnings call: Aetna has been tacking on acquisitions this year as it diversifies its operations, including its deal to acquire Prodigy Health Group, an administrator of self-funded health care plans. Providing self-funded options for mid-sized and small businesses is an area where health insurers have been seeking growth. By Tess Stynes Published July 35 Self-Funding Employee Benefits: No Longer Just for Big Companies Posted by J.P. Farley Corporation on Wed, Dec 08, 2010 Whether it’s the fact that a few healthcare reform measures will not apply to self-funded group health plans on January 1st or the recent availability of new, user-friendly stop loss products in the marketplace, the fact is we are experiencing renewed interest in self-funding of group employee benefits, especially by smaller groups. 36 Utah Group Rate Bands 2.5 2.0 1.5 1.0 0.5 0.0 1 2 3 Average 4 5 6 Lower Band 37 7 8 Upper Band 9 10 Pre vs Post Reform Fully-Insured vs ASO 33 Subscribers, Teaser Rate, PMPM Current Post Reform ASO Claims Medical Claims $135.08 $135.08 Spec+Agg ($0 Margin) $102.05 ASO Claims Total Claims $33.03 $135.08 $135.08 $135.08 $17.04 $17.04 $17.04 SG&A Admin MRM Fee $5.00 Premium Tax $0.85 $1.12 Commissions $8.52 $8.52 $8.52 $26.41 $26.68 $30.56 $8.91 $62.45 $0.00 SG&A Total Profit Medical Stop Loss $11.34 ASO Fee $2.50 Total Profit 38 $8.91 $62.45 $13.84 Exp. Employer Cost $170.40 $224.21 $179.48 Min Employer Cost $170.40 $224.21 $146.45 Max Employer Cost $170.40 $224.21 $213.25 What happens when the healthiest proportion of the population leaves? Population Reduction 0% 5% 10% 20% 25% 50% Average Claims Increase $250 $263 $278 $313 $333 $485 39 What happens when you attract the sickest proportion of the population? Sickest Proportion 5% 6% 7% 8% 9% 10% Average Claims Change $250 $274 $299 $324 $348 $373 40 Number 3: YOU MIGHT BE AN ACTUARY IF • Your wife has insomnia, so she rolls over and says: …“tell me again, darling. What do you do for a living?” Minimum Loss Ratio Large Group – 85% Small Group – 80% Individual – 80% 42 Massachusetts Exchange Case Study 2004 MLR% 2009 Change BCBS MA BCBS MA (HMO) Aetna Neighborhood Health Plan United Health New England Tufts 86% 78% 86% 85% 78% 79% 89% 92% 88% 90% 95% 87% 85% 92% 6% 10% 4% 10% 9% 6% 3% Average(1) 83% 90% 7% Source: Pioneer Institute Public Policy Research (March 2010) (1) Straight average 43 Margin by Market (excluding Credibility) 10% 8% 8% 8% 8% 6% 6% 6% 5% 4% 4% 4% 3% 2% 3% 2% 2% 1% 1% 1% 0% 0% -1% -1% -2% -2% -4% -4% -5% -6% No Waiver Waiver 44 Individual Expenses & Margin: Today vs. 2014 100% 1%, or $2 PMPM 4%, or $10 PMPM 3% 1% 10% 90% 5% 80% 9% 70% 60% 50% 92% 40% 75% 30% 20% 10% 0% Today Medical Costs 2014 Brokers U/W & Other Variable 45 All Other SG&A Profit Individual Expenses & Margin: Today vs. 2014 $300 $250 $10.00 $7.50 $2.50 $200 $150 $1.60 $16.00 $8.00 $14.40 $230.00 $100 $120.00 $50 $0 Today Medical Costs 2014 Brokers U/W & Other Variable 46 All Other SG&A Profit Number 2: YOU MIGHT BE AN ACTUARY IF • Your personality is the only contraceptive you need. Drivers of Adverse Risk Number/Type of Specialist Number/Type of Hospitals Marketing Materials Travel Distance Product Design Age Rating Slope Level of Medical Management Service Levels Disease Management Programs 48 3Rs: Reinsurance, Risk Corridors, Risk Adjustment Transitional Reinsurance Program • Reduce the uncertainty of risk in individual market by making payments for high cost cases Risk Corridor Program • Protect against uncertainty in setting rates in the Exchange by limited insurer gains and losses Risk Adjustment Program 49 • Provide payments to insurers that attract high-risk populations and recoup payments from those attracting lower risk Product Selection Cost by metal category $450 $390 $400 $350 $325 $303 $300 $275 $250 $225 $203 $200 $150 $175 $140 $100 $50 $0 Bronze Silver Gold Pricing Actual 50 Platinum Program Overview Program Reinsurance Risk Corridors Risk Adjustment Objective Provide funding to plans that enroll highest cost individuals Limit insurer loss and gains Transfer funds from lowestrisk plans to highest-risk plans Oversight State or State-option if no State-run Exchange HHS State Option in a State-Run Exchange Participants All Insurers/TPAs contribute funding; non-grandfathered individual market plans (in/out of Exchange) are eligible All individual and SHOP Exchange Qualified Health Plans Non-grandfathered individual and small group market plans inside and outside the Exchange Timing Throughout the year After reinsurance and risk adjustment After end of benefit year Duration 2014-2016 2014-2016 Permanent 51 3Rs: Big Open Issues Issue Open Issue Reinsurance Program • Should HHS develop a national contribution rate or a state-level allocation? • Should assessments be based on a percent of premium or a per capita fee? • What is the right timing for reinsurance payments? • How long should carriers have to submit reinsurance claims? • How much flexibility should states have to design their reinsurance program? Risk Adjustment Program • What standards should HHS adopt to certify state-based programs? • How long after the close of the year should risk adjustment be completed? • When should states make payments to high-risk plans or seek payments from low-risk plans? • What factors/content should be included in risk adjustment model notices? • What standards should be used to validate risk adjustment data? Risk Corridors • How should risk corridor payments interact with the MLR process? • Should activities that improve health care quality for MLR purposes count toward allowable costs for risk corridor calculations? • How often should QHPs make risk corridor payments to HHS? 52 Number 1: YOU MIGHT BE AN ACTUARY IF Instead of getting slapped in the face for getting fresh with your date, she slaps you because she’s afraid you’re dead! 5 3 Questions?
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