One week before the beginning of the 2020 open enrollment period on November 1, the Centers for Medicare and Medicaid Services (CMS) announced that consumers could preview new plans and prices at HealthCare.gov and CuidadodeSalud.gov. This “window shopping” allows consumers to consider their plan options without logging in, creating an account, or completing an official application.
CMS also summarized operational and other changes to HealthCare.gov for the 2020 open enrollment period. The new information complements more comprehensive data released by CMS last week about the 2020 open enrollment period.
The 2020 open enrollment period is the first year that CMS will display five-star quality rating information for most qualified health plans sold through HealthCare.gov. The star rating will be displayed towards the top of each plan and included on side-by-side plan comparisons. Previously, ratings were only available in five states through HealthCare.gov and some state-based marketplaces.
The quality ratings reflect clinical quality data and enrollee satisfaction data, and a rating of three or above means that a plan is considered average or above average compared to other plans across the country. For 2020, 80 percent of plans received a rating of at least three stars. CMS also released quality rating public use files for use by researchers and other interested parties.
New HRA Resources
This will also be the first year that employers can offer a new health reimbursement arrangement (HRA) option to employees to purchase coverage in the individual market. Employers can offer this new HRA pursuant to a new rule finalized in June 2019 and a proposed rule issued in September 2019.
The offer of an individual coverage HRA has implications for whether a consumer qualifies for marketplace subsidies (or not). If an employer offers an individual coverage HRA to an employee and the HRA meets the standard of being “affordable” and of “minimum value,” the employee and their family do not qualify for premium tax credits. If an employer offers an individual coverage HRA to an employee and the employee accepts the HRA, the employee and their family also do not qualify for premium tax credits (even if the HRA was not “affordable” or of “minimum value”).
To help employers and employees understand their options, CMS developed new educational tools and an updated affordability tool for employers. The affordability tool will help employers determine whether an individual coverage HRA is considered “affordable” for purposes of the employer mandate.
Insurer Participation by County
CMS released a new map showing insurers’ county-level participation in the individual market for 2020. County coverage continues to improve: 28 states will have counties with more insurers relative to 2019. For readers interested in understanding how county-level participation has changed over time, the Robert Wood Johnson Foundation updated its interactive tool on insurer participation to include the 2020 plan year. The tool now reflects data from 2015 through 2020 and allows users to track the participation of individual insurance companies or categories of health insurers (such as national carriers or Medicaid managed care companies).
No Major Operational Changes For HealthCare.gov For 2020
CMS enhanced its mobile optimization and filters for the “find local help” tool to allow consumers to search for help by experience and name. As previously discussed, HealthCare.gov will have similar scheduled maintenance windows as last year that coincide with historically low traffic periods. CMS also expanded its streamlined application to improve the consumer experience and handle nearly all consumer applications, regardless of complexity.
Many other HealthCare.gov operations will remain the same as last year. CMS will continue to use the same re-enrollment process and a “waiting room” if needed. The call center will be up and running with representatives trained to handle high consumer demand. As was also true in recent years, consumers can take advantage of a “help on demand” feature to connect directly with available agents and brokers, and small employers will enroll directly with an insurer or through an agent or broker to access the Small Business Health Options Program marketplace. CMS intends to release weekly enrollment snapshots throughout the open enrollment period.
Marketing And Outreach
Like the past two years, CMS will only spend $10 million on marketing and outreach. This is a sizeable reduction from prior years when funding for advertising and outreach was $100 million. CMS will target uninsured people and those planning to reenroll in coverage, with an emphasis on young and healthy consumers. Marketing tactics will be similar to previous years and include YouTube videos, social media, mobile and search advertising, email, text messaging, and autodial messages. According to CMS, targeted email remains the most cost-efficient and effective way to reach consumers.
Critics of CMS’s marketing and outreach cuts argue that they depress new enrollees (who tend to be younger and healthier and thus help maintain a stable risk pool) from entering the marketplace. This trend has played out over time: the number of new enrollees through HealthCare.gov has fallen each year since the 2016 open enrollment period. For 2016, 39 percent of all enrollees were new enrollees. For 2019, this had fallen to 24 percent. Without additional investments in marketing and outreach, it is unlikely that CMS will reverse this trend during the 2020 open enrollment period.
More Enhanced Direct Enrollment
CMS touted that enhanced direct enrollment (EDE) will be available throughout the duration of this year’s open enrollment period. As regular readers know, EDE allows a consumer to complete the entire marketplace enrollment process on the website of a third party, such as a web broker or an insurer. Consumers can thus apply for coverage, be determined eligible for financial help, and enroll in a marketplace plan on a single third-party website without ever visiting or creating an account with HealthCare.gov.
HealthSherpa was the first entity to be approved as an EDE partner in early December 2018, meaning no EDE partner has yet been operational for the full 45-day open enrollment period. Since then, CMS has approved four additional entities (all web brokers or direct enrollment technology providers) to host the EDE platform and 22 entities (all insurance companies) to use the EDE platform.