GA’s Affordable Care Act Exchange Model Moves to Public Comment

September 08, 2020 - CMS has confirmed that Georgia’s Section 1332 state innovation waiver, which changes the Affordable Care Act exchange model, is complete. The waiver will now move into a public comment period.

This waiver has been the source of much contention between the governor’s administration and healthcare experts and associations.

As it currently stands, the state innovation waiver would shift Georgia’s individual health insurance marketplace from HealthCare.gov to its Georgia Access Model. It would also pursue a reinsurance program through tiered coinsurance.

Instead of using HealthCare.gov, the state would work with private entities to establish places for enrollees to purchase exchange health plans alongside qualified health plans and catastrophic plans.

“By enabling all plans licensed in the state to be offered side-by-side with QHPs and Catastrophic Plans, consumers will be able to view the full range of options available to them within the State and select the plan that best suits their needs and price point,” the executive summary argued.

“The goal is to increase healthcare coverage across the State, without eroding the QHP market to provide consumers expanded options.”

According to the executive summary, the reinsurance part of the waiver would place all individual health insurance market members in one risk pool. This should incentivize payers to offer health plans more broadly across the state.

The state expects the reinsurance program to stabilize the market, reducing premiums by over ten percent. The executive summary also stated that it would create more creative competition.

The proposal projected that the Georgia Access Model would increase individual health insurance market enrollment by 25,000 and, as a result, bring down premiums by 3.5 percent. The cost to fund this project would be $144 million for its starting year 2022.

The Brookings Institute, a left-leaning think tank, published an article on the potential impacts of these changes shortly after CMS approved the waiver to move into the next stage.

The authors asserted that the waiver—now in its third iteration, attributing some of the most recent draft changes to coronavirus-related circumstances—would lead to thousands of Georgians losing their insurance and did not take into account certain factors that could lead to higher premiums in the state.

While it does not eliminate the state’s Affordable Care Act exchange, it takes away access through HealthCare.gov and does not institute a state-based marketplace, working through private vendors instead.

Offering plans through vendors is something that the state already does, the authors pointed out. In fact, 21 percent of the state’s enrollment in plan year 2020 was through commissioned vendors. The draft does nothing to attract new vendors, the article stated.

Since the draft never addresses the fact that Medicaid beneficiaries enroll through HealthCare.gov and commits various other analytical errors, the Brookings Institute researchers estimated that instead of adding 25,000 enrollees, the proposal could actually cost the state over 50,000 Marketplace enrollees and 10,000 Medicaid enrollees.

Georgia’s innovation waiver is open for public comment until September 16, 2020.

Other states have also made changes to their exchanges and Medicaid programs even in the midst of the coronavirus pandemic.

The exact impact that the Affordable Care Act exchanges have made is currently hard to discern, as retrieving reliable data can be a challenge. Various studies have come to different conclusions about the level of employer-sponsored health plan losses and where those who have lost their coverage will go.

Still, the Affordable Care Act exchanges have played some role in supporting the unemployed through the crisis, as millions of those in vulnerable industries could be eligible for subsidies on the exchange. On their exchanges, payers have been leveraging special enrollment periods to cover the newly uninsured or underinsured.

In expectation of a surge in enrollment, some states bolstered their Affordable Care Act exchanges. For instance, near the beginning of the crisis CMS approved a waiver for Florida that enabled quicker enrollment and reduced access to care barriers.

Many states chose to add or extend special enrollment periods. Some of these states saw significant spikes in enrollment during these special enrollment periods, in some cases seeing as much as a 250 percent higher enrollment in a 2020 special enrollment period as opposed to a 2019 special enrollment period that occurred around the same timeframe.