Lot’s of talk about the suspension of the ACA’s Risk Adjustment Payments to Insurers. Is this critical or just another scapegoat?

I’d bet you lunch, anywhere in town, that 99% of Americans have no idea what this risk adjustment program (RAP) is or what it does or why it was implemented by the ACA. I’d also wager that 99% of Americans are unaware of the inequities and issues the RAP created.

So, for the 99% of us – what the heck is this Risk Adjustment Program?
The idea was hatched, during the creation of the ACA, as Insurers voiced their fears that Insurers would be inundated with new applicants who had no prior coverage and whose potential healthcare cost (in other words amount of new claims) was impossible to determine. Couldn’t blame the Insurers for their concern, especially when it could be $$billions of dollars in claims on members who had no previous coverage. Plus, the ACA needed a way to entice Insurers to the table.

So, to offer some comfort for planning, the ACA created a complex formula primarily applying to individual plans, that was supposed to level the playing field, so to speak. If one insurer got hit with an inordinate amount of claims while other Insurers did not then the RAP was designed to equal out the pain.

For example: suppose there are just two Insurers offering and accepting applicants in an area, Insurer #1 and Insurer #2. Also, to make the example easier to understand let’s assume that both Insurers  end up covering 1,000 individuals. But, for what ever reason, Insurer #1’s members are all healthy people under 40 years old while Insurer #2’s members are all above 40 years old with a bunch of 60+ and the entire lot is unhealthy.

Obviously, the claim costs for Insurer #2 would be expected to be much higher than Insurer #1. If the claims experience for #2 exceeds 100%, thus loses money, then the loss would have been shared by #1 making payments into the RAP program. Theoretically, every plan should have had this potential cost factored into its plans so that it was a pass through.

Now, the Courts has ruled that the ACA’s RAP payment methodology is flawed which has caused any movement by the Feds to issue RAPs to be suspended. Actually, I don’t think this is a bad think for a couple reasons. One is that Government methodology in almost every initial program is often flawed but seldom corrected. This provides a chance for correction.

Another reason why this halt may be good is that some Insurer’s planning and pricing for initial their plans may have been skewed in an attempt to “game” the RAP.  Your humble author can report on this matter directly. I had conversations with more than one Insurer representative concerning this matter. It was widely agreed that pricing individual plans for the ACA was extremely difficult but more than once I heard “it really does not make a difference because if we’re priced too low and lose money the Gov will make us whole”

The first couple times I heard that sentiment it confused me. I thought, “How could an Insurer not be worried about underpricing their plan?”. The it hit me.

The ACA was designed to be an entitlement plan. Most folks agree that it is an entitlement for the people subsidized under the state run Exchanges. But, did you ever consider that it was an entitlement for the Insurers, too?

How else could the ACA convince Insurers to offer Individual plans with GI and no pre-ex to people who had no prior coverage or worse had been decline for previous coverage.

Now, 7 years in to the ACA and we can see a clearer picture. The big Insurers, you know them, are making money, even though they plead poverty, because they have increased their premiums 300% to as much as 900% in some areas. But, small Insurers and regional Insurers have not done so well because the RAP may have taken money from them to give to the bigger national Insurers.

Of course the battle cry, incited by the ACA supportive Press, is printing headlines about premiums increasing because of the Trump administration’s decision to suspend RAP payments. We should remember:

  1. The Trump Team did not make the decision, the Court did. The Trump folks may not be supportive of the ACA or these RAPs but the Court decided that the RAP methodology was flawed.
  2. The carriers are raising rates anyway, often just because the ACA provides cover, and ACA supporters depend on un-informed readers forgetting that premiums have already been increased a zillion percent.
  3. Finally, as stated above, it’s good to suspend a government program once in a while, at least, to verify its accuracy if not its effectiveness.

We’ll hear more about this as we head toward the Fall and the mid-term elections.

But, you and I won’t be fooled because we’re all in this together.

Until next week,

Mark Reynolds, RHU
559-250-2000
mark@reynolds.wtf

 

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