Digging into the details of single-payer healthcare

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Digging into the details of single-payer healthcare
 
Lawmakers on Capitol Hill rolled up their sleeves this week and began to explore what a shift to Bernie Sanders-style “single payer” healthcare would really mean. In a hearing before the House Rules Committee on Tuesday, Congress heard from proponents of M4A and policy experts about the implications of single-payer health coverage, at least as envisioned by a recent bill authored by Rep. Pramila Jayapal (D-WA).

Although the committee does not have direct jurisdiction over Medicare, and Jayapal’s bill may never be introduced onto the floor of the House (since it lacks support from the Democratic leadership there), the hearing gave lawmakers their first chance to publicly probe the proposal, with predictable positions staked out by Democrats and Republicans on the committee.

More hearings are likely later this year, including by the House Budget Committee, which this week received a report it requested from the Congressional Budget Office (CBO) on the topic of single-payer healthcare. While the report does not address specific details about the cost or tax implications of a shift to single payer, it nonetheless provides an outstanding primer on the key questions that will have to be answered as part of any serious attempt to pursue M4A.

The graphic below, taken from the CBO document, poses those questions in a clear and helpful way, and the full report lays out a framework for approaching them. It’s a sober look at the hard problems that need to be faced: provider payment levels, increased wait times, public vs. private financing, access to unproven treatments.

Whatever your view on the topic, we’d highly recommend reading the CBO report in full.

The CBO analyzed what it would take to shift to a single-payer system. Here are 5 takeaways

https://www.fiercehealthcare.com/payer/5-takeaways-from-cbo-s-analysis-a-single-payer-system?mkt_tok=eyJpIjoiTURRNU5HTmpZbU5tT1RFeiIsInQiOiJLcVdxN0dKUU5iaEdMTGtaMG9xbFdtdEgxdXJBbndhTUNyMWN6UTZzbGJhTHFkS3Z4eTRBZkFGNUxcLzlyZUxvMHpOUDRDbmptdGE4aHVoMk4wS1NTYUlWMFVPMmFxNEEzTkJcL1RDODhYa3psN0VkNFhFdTVqYjlDSHltaTdPMUFxIn0%3D&mrkid=959610

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As chatter about “Medicare-for-All” ideas heats up—at least among the field of Democratic presidential hopefuls—the Congressional Budget Office decided to offer its own take.

Well, sort of.

Wednesday, the CBO issued a report that dove into the key considerations policymakers might want to think about before they overhaul the U.S. healthcare into a single-payer system. Putting it mildly, they said, the endeavor would be a “major undertaking.”

They don’t actually offer up specific cost estimates on any of the Medicare-for-All bills floating around, though other researchers put Bernie Sanders’ Medicare-for-All plan at between $32.6 trillion and $38.8 trillion over the first decade.

But the CBO analysts did weigh in on a slew of different approaches to financing, coverage, enrollment and reimbursement that could be built into a single-payer plan.

“Establishing a single-payer system would be a major undertaking that would involve substantial changes in the sources and extent of coverage, provider payment rates and financing methods of healthcare in the United States,” the CBO said.

So what exactly did the CBO have to say about what it would take to create a single-payer system? Here are some key takeaways:

1. There could be a role for private insurance—or not

There has been plenty of heated debate around Medicare for All focused on the role that existing private coverage could—or could not—play in that system. Most insured Americans are enrolled in a private plan today, including about one-third of Medicare beneficiaries.

If they’re allowed, commercial plans could play one of three roles in a single-payer system, according to the report: as supplemental coverage, as an alternative plan or to offer “enhanced” services to members in the government plan. 

Allowing private insurers to offer substitutive plans is unlikely, because they could potentially offer broader provider networks or more generous benefits, which would draw people into them. A solution to this issue could be mandating that providers treat a minimum number of patients who are enrolled in a single-payer plan.

Private payers could also offer coverage for care that is traditionally outside of the purview of government programs, such as dental care, vision care and hearing care.

Supplemental plans like these are offered in the existing Medicare program, and several countries with single-payer systems allow this additional coverage.

For example, in England, private plans offer “enhancements” to members of the government plan, including shorter wait times and access to alternative therapies, But members of these plans must pay for it in addition to tax contributions to the country’s National Health Service. 

2. Other government programs could stick around

In addition to Medicare and Medicaid, the federal government operates several health programs targeting individual populations: the Veterans Affairs health system, TRICARE and Indian Health Services.

A single-payer system could be designed in a way that also maintains these individualized programs, the CBO said. Canada does this today, where its provinces operate the national system while it offers specific programs outside that for indigenous people, veterans, federal police officers and others.

There could also be a continuing role for Medicaid, according to the report. 

“Those public programs were created to serve populations with special needs,” the CBO said. “Under a single-payer system, some components of those programs could continue to operate separately and provide benefits for services not covered by the single-payer health plan.”

On the flip side, though, a single-payer plan could choose to fold members of those programs into the broader, national program as well, the office said. 

3. A simplified system could also mean simplified tech

Taiwan’s government-run health system has a robust technology system that can monitor patients’ use of services and healthcare costs in near real-time, according to the report.  

Residents are issued a National Health Insurance card that can store key information about them, including personal identifiers, recent visits for care, what prescriptions they use and any chronic conditions they may have.  Providers also submit daily data updates to a government databank on service use, which is used to closely monitor utilization and cost. Other technology platforms in Taiwan can track prescription drug use and patients’ medical histories.

However, getting to a streamlined system like this in the U.S. would be bumpy, the CBO said. It would face many of the same challenges the health system is already up against today, such as straddling many federal and state agencies and addressing the needs of both rural and urban providers.

But the payoffs could be significant, according to the report. 

“A standardized IT system could help a single-payer system coordinate patient care by implementing portable electronic medical records and reducing duplicated services,” the agency wrote. 

4. How to structure payments to providers? Likely global budgets

Most existing single-payer systems use a global budget to pay providers, and may also apply in tandem other payment approaches such as capitation or bundled payments according to the report.

How these global budgets operate varies between countries. Canada’s hospitals operate under such a model, while Taiwan sets a national healthcare budget and then issues fee-for-service payments to individual providers. England also uses a national global budget.

Global budgets are rare in the U.S., though Maryland hospitals operate under an all-payer system. These models put more of the financial risk on providers to keep costs within the budget constraints. 

Many international single-payer systems pay based on volume, but the CBO said value-based contracting could be built into any of these payment arrangements.

5. Premiums and cost-sharing are still in play, especially depending on tax structures

A government-run health system would, by its nature, need to be funded by tax dollars, but some countries with a single-payer system do charge premiums or other cost-sharing to offset some of those expenditures.

Canada and England operate on general tax revenues, while Taiwan and Denmark include other types of financing. Danes pay a dedicated, income tax to back the health system, while the Taiwanese have a payroll-based premium. 

The type of tax considered would have different implications on financing, according to the CBO. A progressive tax rate, for instance, would impose higher levies on people with higher incomes, while a consumption tax, such as one added to cigarettes, would affect people more evenly.

Policymakers will also have to weigh when to impose new taxes, shifting the economic burden between generations. 

The CBO did not offer any cost estimates in terms of the amount the federal government would need to raise in taxes to fund a single-payer program.

 

 

 

It Costs $685 Billion a Year to Subsidize U.S. Health Insurance

https://www.bloomberg.com/news/articles/2018-05-23/it-costs-685-billion-a-year-to-subsidize-u-s-health-insurance

 

It will cost the U.S. government almost $700 billion in subsidies this year help provide Americans under age 65 with health insurance through their jobs or in government-sponsored health programs, according to a report from the nonpartisan Congressional Budget Office.

The subsidies come from four main categories. About $296 billion is federal spending on programs like Medicaid and the Children’s Health Insurance Program, which help insure low-income people. Almost as big are the tax write-offs that employers take for providing coverage to their workers. Medicare-eligible people, such as the disabled, account for $82 billion. Subsidies for Obamacare and for other individual coverage are the smallest segment, at $55 billion.

In total, the subsidies are equivalent to about 3.4 percent of the U.S. gross domestic product.

Financing Americans’ Insurance

In 2018, subsidizing health coverage will cost taxpayers almost $700 billion.

Also known as the Affordable Care Act, Obamacare reduced the number of uninsured, but 29 million people will likely go without health coverage in an average month this year, the CBO said. Thirty-five million Americans could lack coverage by 2028 as rising premiums and the elimination of the individual mandate drive more people to drop coverage.

The subsidies in the Affordable Care Act are designed to insulate people in the program from premium increases. The CBO projected that monthly premiums for a mid-range plan in the program will increase by 15 percent by 2019, and by about 7 percent annually through 2028.

One reason for the rising premiums is the actions of President Donald Trump. Last year, Trump topped funding for the cost-sharing reduction payments made to insurers under Obamacare to help Americans afford health costs.

The non-payment of those subsidies, less enforcement of a rule requiring people to have insurance and limited competition caused insurers to raise their premiums by about 34 percent in 2018, compared to 2017. That increased the cost of the subsidies to the federal government, according to the CBO.

Evidence-Based Health Policy

http://www.nejm.org/doi/full/10.1056/NEJMp1709816?query=featured_home&

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In these times of heated rhetoric about what various health care reforms can and cannot accomplish, both hopeful and doomsday stories abound. Proponents and opponents of reforms often claim that their views are grounded in evidence, but it’s not always clear what they mean by that — particularly given the wide range of often incompatible views. Voters, physicians, and policymakers are left to wade through a jumble of anecdotes, aspirations, associations, and well-designed studies as they try to evaluate policy alternatives. Having a clear framework for characterizing what is, and isn’t, evidence-based health policy (EBHP) is a prerequisite for a rational approach to making policy choices, and it may even help focus the debate on the most promising approaches.

EBHP, we believe, has three essential characteristics (see table Illustrative Examples of Health Policies, Possible Goals, and Relevant Evidence Base.). First, policies need to be well-specified; a slogan is not sufficient. For example, “expand Medicaid” isn’t a policy. “Expand existing Medicaid benefits to cover all adults below the poverty line” is closer — but, of course, moving to a specific, implementable program requires vastly more detail. “Target population health” doesn’t qualify as a policy, let alone EBHP, because myriad policies fall under the population health banner, including influenza vaccination, smoking cessation, medication adherence, improving diets, increasing diabetes screening, addressing transportation barriers, and coordinating care. Slogans like “population health,” “single payer,” or “malpractice reform” may be an effective way to signify a political position or rally support (after all, who’s against population health?), but in avoiding specificity, they sidestep the hard work of assessing the relative effectiveness and implementation details of the policies included under their umbrella.

Second, implementing EBHP requires us to distinguish between policies and goals. This distinction is important in part because different people may have different goals for a particular policy. Consider the policy of implementing financial incentives for physicians to coordinate care. The evidence that such incentives would reduce health care spending (one potential goal) is quite weak, whereas the evidence that it might improve health outcomes (a different goal) is stronger.1 Claims that care coordination “doesn’t work” because it doesn’t save money miss the point that it may achieve other goals. Conversely, different policies may vary in their effectiveness at achieving a particular goal. If the goal is to reduce spending, then promoting competition or rate regulation may be more effective than care coordination.

Similarly, consider the policy of raising income limits for Medicaid eligibility. The evidence suggests that this policy is likely to achieve the goal of expanding access to care. On the other hand, evidence from a randomized trial indicates that it’s not likely to achieve the goal of reducing emergency department (ED) use (and even the broader evidence is mixed).2,3 If one favors expanding Medicaid to achieve the normative goal of redistribution from rich to poor and healthy to sick, it is tempting to suggest that expansion would also save money by reducing the use of expensive ED visits. But such claims are at best disingenuous and at worst counterproductive: if the evidence shows that Medicaid doesn’t achieve the stated objective of reducing ED use, that undermines the case for expansion even if the policy might achieve the unstated goal of redistribution. Being clear about goals is the only way to evaluate a policy’s effectiveness and the implied trade-offs between competing goals. These stylized examples are meant to illustrate the key components of the EBHP approach; evidence on each of these policies (and their many variants) is clearly much more nuanced than we can outline here.

Third, EBHP requires evidence of the magnitude of the effects of the policy, and obtaining such evidence is an inherently empirical endeavor. Introspection and theory are terrible ways to evaluate policy. In some instances, we have clear conceptual models that suggest the direction of the effect a policy is likely to have, but these models never tell us how big the effect is likely to be. For example, economic theory says that, all else being equal, when copayments or deductibles are higher, patients use less care (we’re pretty sure that demand slopes down), but this theory doesn’t tell us by how much. And often even the direction of the effect is unclear without empirical research, with different effects potentially going in opposite directions.

What makes for “rigorous enough evidence”? Professional medical societies have developed gauges of the strength of evidence to support clinical guidelines, and we should demand nothing less for health policy. No study is perfect, and important policy questions are rarely answered definitively by any one study. Nor does pointing to a large literature with similar results prove a point if those studies share a common weakness such as an inability to control for confounders. There is a crucial distinction between finding an association between a policy and an outcome (Do people who receive more preventive care spend less on health care? Often yes) and a causal connection (Does delivering more preventive care reduce health care spending? Overall, we think probably not).

There is also a key difference between “no evidence of effect” and “evidence of no effect.” The first is consistent with wide confidence intervals that include zero as well as some meaningful effects, whereas the latter refers to a precisely estimated zero that can rule out effects of meaningful magnitude. These nuances are often lost when “evidence” is deployed in policy debates.

The effect of a policy, of course, also depends on the design and implementation details and the program particulars (Medicaid varies from state to state, for example, and the effect of expansions to different populations may vary) — and evidence needs to speak to those particulars. It is also important to consider the full range of a policy’s effects — its costs and benefits, and how each of these evolves over time.4 An impartial assessment of the budgetary costs like those provided by the Congressional Budget Office (CBO) is a crucial but incomplete part of the picture because of the CBO’s statutory emphasis on the federal budget rather than lives or well-being.

Making health policy on the basis of evidence will always be a fraught and uncertain endeavor, and each component we outline here comes with challenges. For starters, we acknowledge that fully specifying a policy requires the kind of legislative and regulatory detail that is impractical for a high-level policy debate, but often the “policies” being discussed are so ill specified that it’s impossible to bring any evidence to bear.

In addition, just as the distinction between policies and goals is often muddied, interpretations of the evidence are often flavored by the implicit goals of the analyst.5 A given body of evidence can be used to support very different policy positions (depending on what one’s goals are — for example, how one weighs costs to taxpayers versus redistribution of health care resources), but different goals shouldn’t drive different interpretations of the evidence base.

Finally, even a rich body of evidence cannot guarantee that a policy will achieve its goals, and waiting for that level of certainty would paralyze the policy process. In health policy — as in any other realm — it is often necessary to act on the basis of the best evidence on hand, even when that evidence is not strong. Doing so requires weighing the costs of acting when you shouldn’t against those of not acting when you should — again, a matter of policy priorities.

Just because something sounds true doesn’t mean that it is, and magical thinking won’t improve our health care system. EBHP helps separate facts from aspiration. But as important as evidence is to good policy choices, it can’t tell us what our goals should be — that’s a normative question of values and priorities. Better policy requires being both honest about our goals and clear-eyed about the evidence.

 

Grassley Pressing to Include Drug Pricing Measures in CHIP Reauthorization

https://morningconsult.com/2017/10/03/grassley-pressing-include-drug-pricing-measures-chip-reauthorization/

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  • The CREATES Act would crack down on practices employed by some brand-name drugmakers to thwart generic competition.
  • The Preserve Access to Affordable Generics Act targets deals between brand-name drugmakers and their generic counterparts to delay the market entry of competing drugs.

Sen. Chuck Grassley, a senior member and former chairman of the powerful Senate Finance Committee, is pressing GOP leaders to tackle high drug prices in a critical bill to renew funding for the Children’s Health Insurance Program.

Grassley (R-Iowa), who has tried for years to advance legislation targeting rising prescription drug costs to little avail, is pushing two bills as potential offsets for CHIP funding.

Both measures have some bipartisan support, but neither has advanced in previous congressional sessions amid fierce pushback from the pharmaceutical industry. But with urgency on Capitol Hill to renew CHIP, which expired last week, Grassley is taking a shot at getting the bills — the CREATES Act and the Preserve Access to Affordable Generics Act — included in the reauthorization as partial offsets.

The CREATES Act would crack down on practices employed by some brand-name drugmakers to thwart generic competition, while the Preserve Access to Affordable Generics Act targets deals between brand-name drugmakers and their generic counterparts to delay competing drugs from entering the market.

Experts on Grassley’s staff have talked with staff on the Senate Finance Committee and in leadership about the proposals ahead of a committee markup of the CHIP legislation on Wednesday, according to a senior GOP aide.

Supporters from the health sector, which include health insurers, providers and patient organizations, say their chances have never been better, given public outrage at exorbitant drug prices, bipartisan desire to address the issue in Congress and interest in drug prices from within the Trump administration. The proposals have even united progressive advocacy group Public Citizen and the conservative FreedomWorks.

Still, despite unprecedented momentum to tackle rising prescription costs, it is still far from certain whether Grassley will be successful. Senate Finance Committee Chairman Orrin Hatch (R-Utah) has not endorsed either measure and has sometimes sided with brand-name drugmakers on divisive pricing issues. Hatch’s office did not respond to a request for comment on Tuesday.

“It is a delicate conversation between two chairmen who’ve been here for more than a cup of coffee,” Rodney Whitlock, Grassley’s former health policy expert, said in an interview Tuesday. Whitlock is now vice president of health policy at the consulting firm ML Strategies LLC.

Political procedure also complicates Grassley’s effort. Both drug pricing measures have been referred to the Senate Judiciary Committee, which Grassley chairs, while the Senate Finance Committee has jurisdiction over CHIP.

A spokesman for Senate Majority Leader Mitch McConnell (R-Ky.) directed a request for comment to Grassley’s office.

CBO: ObamaCare premiums could rise 20 percent if Trump ends payments

CBO: ObamaCare premiums could rise 20 percent if Trump ends payments

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Insurance companies would raise premium prices about 20 percent for ObamaCare plans if President Trump ends key payments to insurers, according to the Congressional Budget Office (CBO).

At the request of House Democratic leadership, CBO estimated what would happen if the payments to insurers ended after December. It found that halting payments would increase the federal deficit by $194 billion through 2026.

Many people would be cushioned from the impact of the increases because federal tax credits rise automatically when premiums do.

If the payments ended, some carriers would withdraw from ObamaCare and about 5 percent of people would live in an area without any options on the exchanges in 2018, according to CBO. But by 2020, CBO estimates more insurers would participate again, so that most areas would be covered.

The number of people without insurance would be slightly higher next year but a little lower in 2020, according to the analysis.

Cost-sharing reduction payments are made to insurers, compensating them for discounting out-of-pocket costs for certain enrollees.

Insurers have been pleading for certainty from the administration on whether they’ll continue to receive the payments, which total about $7 billion for fiscal 2017.

The administration has been making these payments on a monthly basis. But Trump has threatened to halt the funds, calling the money “bailouts” for insurance companies.

The issue has also been caught up in court, and if Trump decides to stop appealing a court ruling against the administration, CSR payments could stop. The deadline for another update is coming up quick — Aug. 20. The case has been on hold for months and could be delayed again.

Additionally, the Senate Health Committee will hold hearings on a bipartisan, short-term stabilization measure the first week of September. The goal, according to Chairman Lamar Alexander (R-Tenn.), is to craft a bill by mid-September that includes funding the payments to insurers.

But insurers are bumping up against major deadlines.

Last week, the administration extended the deadline for carriers to finalize how much their premiums will cost on HealthCare.gov. That date is now Sept. 5, and insurers sign contracts locking them into selling plans Sept. 27.

If insurers don’t know if CSRs will be funded, they could exit the marketplaces, health experts warn. That could possibly lead to some areas have no insurers selling plans on their exchanges.

 

CBO: Ending cost-sharing reduction payments will increase premiums, federal deficit

http://www.fiercehealthcare.com/aca/cbo-ending-cost-sharing-reduction-payments-will-increase-premiums-federal-deficit?mkt_tok=eyJpIjoiTVdKa1pEazNOMll5WVRreiIsInQiOiJkaVJDVnRHOXNNXC9ENmt6WFpTTFwvZGVQeThhQVRjZHR2VE9jUEVQQUtlZ3BxUFg0akRMM0FOK2hWZUc4ajJ4WVdzOUV3Z21GM1cyU1VVOWNDekZ2aVwvZG11VnFVVDQ3WEJvejBQU3ZVZTM4bjZyK3A1VjlcL3Q0Mmtsc3VJUTErS0wifQ%3D%3D&mrkid=959610&utm_medium=nl&utm_source=internal

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If the Trump administration stops funding cost-sharing reduction payments, silver-plan premiums on the Affordable Care Act exchanges will rise considerably and the federal deficit will increase, the Congressional Budget Office said Tuesday.

Officially, the administration remains undecided about how long it will continue making CSR payments, which are at the center of a federal court case that challenges their legality. Many insurers have had to factor this uncertainty into their preliminary rate filings.

To map out the consequences of one possible move by the administration, the CBO examined what would happen if federal officials announced at the end of August that they would continue CSR payments through the end of the year but discontinue them after that.

That policy would result in silver-plan premiums rising by an average of 20% in 2018 and 25% by 2020, the CBO estimates. Because tax credits rise in tandem with premiums, most eligible enrollees would not pay higher rates than they would if CSR payments continued—though the report also notes that overall, “the share of people facing slight increases would be higher during the next two years.”

Since more people would likely receive premium tax credits and in greater amounts, the CBO predicts that ending CSR payments would raise the federal deficit by $6 billion in 2018, $21 billion in 2020 and $26 billion in 2026.

The CBO also predicts that ending CSR payments would cause some insurers to exit the individual marketplaces, leaving about 5% of people living in areas that have no ACA exchange insurer in 2018. However, the agency predicts that more insurers would likely return to the exchanges in 2020 after having adjusted to the new policy.

Overall, the number of uninsured people would be slightly higher in 2018 but slightly lower starting in 2020 under the scenario the CBO examined, per the report.

CBO to release analysis of ending key ObamaCare insurer payments

CBO to release analysis of ending key ObamaCare insurer payments

CBO to release analysis of ending key ObamaCare insurer payments

The nonpartisan Congressional Budget Office (CBO) will release an analysis next week detailing the effects of ending key ObamaCare insurer payments.

The CBO announced Friday the score would be released next week.

President Trump has threatened to cancel the payments, known as cost-sharing reductions, which reimburse insurers for giving discounted deductibles and copays to low-income people.

The administration has made the payments on a month-to-month basis but insurers have pleaded for long-term certainty.

The reimbursements total $7 billion for fiscal 2017, and regardless of whether the administration pays them, insurers would still be on the hook to offer these discounts to enrollees — they just wouldn’t be reimbursed for doing so.

Uncertainty over the future of the payments has contributed to insurers exiting the healthcare exchanges and proposed premium increases for 2018. More insurers might leave or increase premiums if the payments aren’t continued.

The Senate Health Committee will hold bipartisan hearings in September on ways to stabilize and strengthen the individual market.

The goal is to craft a bipartisan, short-term proposal by mid-September, which could include funding the payments.

The Effects of Ending the Affordable Care Act’s Cost-Sharing Reduction Payments

The Effects of Ending the Affordable Care Act’s Cost-Sharing Reduction Payments

Controversy has emerged recently over federal payments to insurers under the Affordable Care Act (ACA) related to cost-sharing reductions for low-income enrollees in the ACA’s marketplaces.

The ACA requires insurers to offer plans with reduced patient cost-sharing (e.g., deductibles and copays) to marketplace enrollees with incomes 100-250% of the poverty level. The reduced cost-sharing is only available in silver-level plans, and the premiums are the same as standard silver plans.

To compensate for the added cost to insurers of the reduced cost-sharing, the federal governments makes payments directly to insurance companies. The Congressional Budget Office (CBO) estimates the cost of these payments at $7 billion in fiscal year 2017, rising to $10 billion in 2018 and $16 billion by 2027.

The U.S. House of Representatives sued the Secretary of the U.S. Department of Health and Human Services under the Obama Administration, challenging the legality of making the cost-sharing reduction (CSR) payments without an explicit appropriation. A district court judge has ruled in favor of the House, but the ruling was appealed by the Secretary and the payments were permitted to continue pending the appeal. The case is currently in abeyance, with status reports required every three months, starting May 22, 2017.

If the CSR payments end – either through a court order or through a unilateral decision by the Trump Administration, assuming the payments are not explicitly authorized in an appropriation by Congress – insurers would face significant revenue shortfalls this year and next.

Many insurers might react to the end of subsidy payments by exiting the ACA marketplaces. If insurers choose to remain in the marketplaces, they would need to raise premiums to offset the loss of the payments.

We have previously estimated that insurers would need to raise silver premiums by about 19% on average to compensate for the loss of CSR payments. Our assumption is that insurers would only increase silver premiums (if allowed to do so by regulators), since those are the only plans where cost-sharing reductions are available. The premium increases would be higher in states that have not expanded Medicaid (and lower in states that have), since there are a large number of marketplace enrollees in those states with incomes 100-138% of poverty who qualify for the largest cost-sharing reductions.

There would be a significant amount of uncertainty for insurers in setting premiums to offset the cost of cost-sharing reductions. For example, they would need to anticipate what share of enrollees in silver plans would be receiving reduced cost-sharing and at what level. Under a worst case scenario – where only people eligible for sharing reductions enrolled in silver plans – the required premium increase would be higher than 19%, and many insurers might request bigger rate hikes.