Overlap Issuers: Possible Drivers of Premium Reductions: June 2020


Nearly 11.5 million consumers signed up for coverage through the Federal Health Insurance Marketplace or individual State Based Marketplaces for 2020.[1] However, in a typical year, some Marketplace consumers will only be enrolled for part of the year.[2] Some of these consumers become uninsured or switch to a group plan through their job. Others, owing to changes in income, gain Medicaid eligibility at some point during the year. The regular flux in enrollment has been exacerbated by the COVID-19 pandemic, leading to millions more Americans losing coverage and cycling through different types of coverage. Health Management Associates (HMA) recently estimated a potential growth in Medicaid nationwide of 5 to 18 million enrollees by the end of this year, with slow decreases based on the speed of recovery to an eventual .5 to 4.5 million more Medicaid enrollees by the end of 2022 compared to the end of 2019.[3] Many of these enrollees will move between Medicaid and private coverage as their incomes change. As HMA notes, “Enrollment in the individual Marketplace is projected to see significant turnover, as people will both enter [from the job-based coverage market] and exit [into Medicaid] due to job losses and have associated changes in income.”[4]

The Association for Community Affiliated Plans (ACAP) is interested in better understanding the landscape for consumers that move between the individual market and Medicaid and the role of “overlap issuers”—those that offer Marketplace and Medicaid MCO coverage in the same state. As an association representing Medicaid issuers, some of which have entered the new individual market, ACAP has noted that such issuers in particular may play an important role in driving down premiums.

A new analysis of the data suggests a correlation between overlap plans and lower premiums in a given Marketplace.

ACAP finds for the 2020 benefit year that overlap issuers generally offer lower-priced products than other issuers on the individual market. Additionally:

  • Marketplaces in 34 states include at least one overlap issuer. As 39 states (inclusive of the District of Columbia) offer Medicaid Managed Care, overlap plans are present in 87% of states where they are possible.
  • In more than three-quarters of states offering coverage from an overlap issuer, an overlap issuer offered either the lowest or second-lowest silver-level premium in the state for a 27-year-old.
    • In 81 percent of rating areas with an overlap plan, the overlap plan offers either the lowest or second-lowest silver-level premium for a 27-year-old; this is a slight decrease from 2019.
  • Eight states experienced a net gain in overlap issuers compared with 2019; six had a net loss.
  • The total number of Qualified Health Plans (QHP) participating in the Marketplace[5] rose from 219 to 258, an 18% increase over last year.
  • 102 of the 258 QHP issuers (40%) offering Marketplace coverage are overlap issuers. The percentage of overlap issuers nationwide has remained steady since ACAP began tracking this data in 2014, generally ranging in the low-to-mid 40s.

See full report here (.pdf) >>

Download analysis spreadsheet here (.xlsx) >>


[1] Centers for Medicare & Medicaid Services. (2020). “Health Insurance Exchanges 2019 Open Enrollment Report.

[2] CMS. (2017). “First Half of 2017 Average Effectuated Enrollment Report.”

[3] Health Management Associates. (2020). “COVID-19 Impact on Medicaid, Marketplace, and the Uninsured. May 2020 Update.”

[4] Health Management Associates. (May 20, 2020). “HMA Weekly Roundup: Trends in Health Policy.”

[5] ACAP counted the number of unique issuers offering QHP plans in each state. As an example, Centene offers QHP plans across many different states. Under this methodology they are counted separately across states rather than once.