According to a new report from the Kaiser Family Foundation, eliminating cost sharing reductions (CSRs), or subsidies that lower the out-of-pocket costs for moderate-income consumers, would increase overall costs to federal government instead of saving money.
Nationally, CSRs are worth approximately $7 billion annually and reduce out-of-pocket costs for moderate income consumers by $3,350 to $3,600 per year.
CSRs are especially important for New York because CSRs provide nearly $1 billion annually in funding for the Essential Plan, the State’s Basic Health Program, which covers nearly 700,000 New Yorkers.
Continued funding for CSRs is at risk. In 2016, members of the House of Representatives sued the Administration to block funding for CSRs and argued that the Administration had paid for them without Congressional authority. A district court ruled in favor of the House, and the case is now on appeal. The current Administration now has to decide whether or not to move forward with the appeal. If the appeal is dropped, and Congress does not appropriate the CSR funding, millions of consumers may no longer be able to afford coverage.
Although it would appear that eliminating CSRs would save the federal government money, the Kaiser Family Foundation explains that any savings would be coupled with significant increases in costs for the Advanced Premium Tax Credits (APTCs) that lower monthly premiums. The report estimates that ending CSRs would actually result in a net increase in federal costs of $2.3 billion.
Last week, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule for 2018. According to the press release, the proposed rule includes “reforms that are critical to stabilizing the individual and small group health insurance markets to help protect patients.”
However, many of the policy changes in the proposed rule would harm consumers. For example, a recent analysis from the non-partisan Center on Budget and Policy Priorities explains that the proposed rule would reduce the advanced premium tax credits that help make plans purchased through the Marketplace more affordable for moderate-income individuals in families.
According to the analysis, the proposed rule would result in lower tax credits because it lowers the actuarial value standards for “silver” level plans. This means that premiums and the percentage of costs covered by the insurer would decrease, but deductibles and copayments for consumers would increase. Under the Affordable Care Act, tax credits for consumers purchasing coverage through the Marketplace are calculated based on the second lowest cost silver plan. By allowing for lower value silver plans, the new rule would force consumers to pay more out of pocket to maintain their current level of coverage.
Furthermore, the CMS proposed rule also includes provisions to require consumers to provide supporting documentation for special enrollment periods before they can enroll in coverage. The proposed rule would also permit insurance companies to collect any missed premium payments before allowing consumers to re-enroll. Both of these changes could lead to gaps in coverage for consumers or deter enrollment.
Finally, the proposed rule would reduce the open enrollment period for individual and small group health insurance plans from 13 weeks to 6 weeks, which would give consumer significantly less time shop around for and enroll in the best plan for them.