Implications Of CMS Mandating A Broad Load Of CSR Costs

May 15, 2018

In October 2017, the Trump administration eliminated federal funding to reimburse insurers for cost-sharing reduction (CSR) subsidies, which they are obligated to provide to qualifying enrollees in the Affordable Care Act (ACA) Marketplace. President Donald Trump had threatened to eliminate CSR funding throughout 2017, so insurers and insurance regulators in many states had anticipated the move by adding the cost of CSRs to premiums for 2018.

In the days following the elimination of CSR funding, 48 of 51 states (all but North Dakota, Vermont, plus the District of Columbia) allowed insurers to add CSR costs to 2018 premiums in some manner. To compensate insurers for the cost of CSRs, five states used a “broad load” uniform surcharge that applied to all individual policies on and off the exchanges. All other states used some variant of a “silver load,” in which the cost of CSRs was added only to silver-plan premiums. A spreadsheet with each state’s approach is available here. All of this was done in a hodge-podge fashion in 2017, with insurers and state regulators unsure what would happen at the federal level, and the official termination of CSR funding coming less than three weeks before the start of open enrollment.  

Read more from David Anderson and colleagues on the Health Affairs Blog.