policy as a supplemental source of coverage in 2010 nearly ......the structure of medigap policies...

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Medigap Reform: Setting the Context for Understanding Recent Proposals Gretchen Jacobson, Jennifer Huang, and Tricia Neuman INTRODUCTION In recent years, policymakers have focused on a wide range of options to inform the national debt reduction debate, including proposals to help reduce Medicare spending by reforming the current Medicare supplemental insurance (Medigap) market. Due to Medicare’s relatively high cost-sharing requirements, the vast majority of beneficiaries have some source of coverage that supplements Medicare, including 9 million Medicare beneficiaries who purchase Medigap policies. Some beneficiaries with Medigap policies also have other sources of supplemental coverage, including coverage from employer or union-sponsored retiree health plans, the Department of Veterans Affairs (VA) or Medicare Advantage plans. Nationwide, nearly one in four of all Medicare beneficiaries had a Medigap policy in 2010, including beneficiaries with multiple sources of supplemental coverage (Exhibit 1). Among beneficiaries in traditional Medicare (excluding people in Medicare Advantage), more than one in four (26%) has a Medigap policy. 1 In some states, enrollment is much higher than the national average. As described later in the brief, about half of all beneficiaries in five states had a Medigap policy (IA, KS, ND, NE, and SD). Most Medigap enrollees (86%) live on incomes below $40,000 per person, and nearly half (47%) have incomes below $20,000 per person. This issue brief contextualizes recent proposals to change Medigap plans in order to understand how they may affect Medicare beneficiaries, using recently available data. The brief begins with an overview of Medigap’s role in providing supplemental coverage for Medicare beneficiaries. It then presents the most current data available on Medigap enrollment and premiums, by state, beneficiary characteristic, and plan type, 2 and describes recent Medigap proposals that have emerged as part of efforts to reduce Medicare spending. Exhibit 1 SOURCE: Kaiser Family Foundation analysis of the CMS Medicare Current Beneficiary Survey Cost and Use File, 2010. Nearly one in four Medicare beneficiaries had a Medigap policy as a supplemental source of coverage in 2010 Other Public/Private Coverage only 1% 15% Medigap only 4% Medigap + Employer 2% Medigap + Medicare Advantage 2% Other coverage combinations (including Medigap) Total Medicare Beneficiaries, 2010 = 48.4 Million Medicare Advantage only 13% Medicaid only 14% Employer- Sponsored only 26% No Supplemental Coverage 14% Medigap 23% Multiple Sources of Coverage (without Medigap) 9%

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Page 1: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

Medigap Reform: Setting the Context for Understanding Recent Proposals

Gretchen Jacobson, Jennifer Huang, and Tricia Neuman

INTRODUCTION

In recent years, policymakers have focused on a

wide range of options to inform the national debt

reduction debate, including proposals to help

reduce Medicare spending by reforming the

current Medicare supplemental insurance

(Medigap) market. Due to Medicare’s relatively

high cost-sharing requirements, the vast majority

of beneficiaries have some source of coverage that

supplements Medicare, including 9 million

Medicare beneficiaries who purchase Medigap

policies. Some beneficiaries with Medigap policies

also have other sources of supplemental coverage,

including coverage from employer or union-sponsored retiree health plans, the Department of Veterans Affairs

(VA) or Medicare Advantage plans.

Nationwide, nearly one in four of all Medicare beneficiaries had a Medigap policy in 2010, including

beneficiaries with multiple sources of supplemental coverage (Exhibit 1). Among beneficiaries in traditional

Medicare (excluding people in Medicare Advantage), more than one in four (26%) has a Medigap policy.1 In

some states, enrollment is much higher than the national average. As described later in the brief, about half of

all beneficiaries in five states had a Medigap policy (IA, KS, ND, NE, and SD). Most Medigap enrollees (86%)

live on incomes below $40,000 per person, and nearly half (47%) have incomes below $20,000 per person.

This issue brief contextualizes recent proposals to change Medigap plans in order to understand how they may

affect Medicare beneficiaries, using recently available data. The brief begins with an overview of Medigap’s role

in providing supplemental coverage for Medicare beneficiaries. It then presents the most current data

available on Medigap enrollment and premiums, by state, beneficiary characteristic, and plan type,2 and

describes recent Medigap proposals that have emerged as part of efforts to reduce Medicare spending.

Exhibit 1

SOURCE: Kaiser Family Foundation analysis of the CMS Medicare Current Beneficiary Survey Cost and Use File, 2010.

Nearly one in four Medicare beneficiaries had a Medigap policy as a supplemental source of coverage in 2010

Other Public/Private Coverage only

1%

15% Medigap only

4% Medigap + Employer

2%Medigap + Medicare Advantage

2%Other coverage combinations (including Medigap)

Total Medicare Beneficiaries, 2010 = 48.4 Million

Medicare Advantage

only13%

Medicaid only14%

Employer-Sponsored

only 26%

No Supplemental

Coverage14%

Medigap

23%

Multiple Sources of Coverage

(without Medigap)

9%

Page 2: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

Medigap Reform: Setting the Context for Understanding Recent Proposals 2

MEDIGAP’S ROLE FOR BENEFICIARIES

Medicare provides broad protection against the costs of many health care services, but has relatively high cost-

sharing requirements and significant gaps in coverage. Traditional Medicare has deductibles for Parts A

(inpatient) and B (physician and outpatient) services, 20 percent coinsurance for most Part B services,

coinsurance for inpatient hospital and skilled nursing facility stays exceeding 20 days, and no maximum on the

amount beneficiaries could incur in out-of-pocket costs each year (Table A1). As a result, most beneficiaries

covered under traditional Medicare have some form of supplemental coverage to help cover cost-sharing

expenses required for Medicare-covered services.

Since the early years of the Medicare program, a substantial share of the Medicare population has relied on

Medigap to help with Medicare’s cost-sharing requirements. Medigap enrollees tend to include beneficiaries in

traditional Medicare who do not have access to an employer or union-sponsored retiree health plan and

beneficiaries who are not poor enough to qualify for Medicaid. Medigap policies have helped to shield

beneficiaries from sudden, out-of-pocket costs resulting from an unpredictable medical event, and have

allowed beneficiaries to more accurately budget their health care expenses, which is important to a population

living on fixed incomes. Because Medicare and private Medigap insurers generally coordinate payments to

providers, Medigap also minimizes the paperwork burden for beneficiaries. In most cases, there are no claims

to check or bills to pay. Even with Medigap, beneficiaries often incur significant out-of-pocket expenses for

services that are not covered by Medicare (such as dental and long-term care) and for costs associated with

prescription drug coverage offered separately by Part D plans.

The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries

more easily compare policies and to address concerns about the marketing and quality of Medigap policies.

Several laws since the 1970s – and in particular, the Social Security Disability Amendments of 1980 (also

referred to as the “Baucus Amendments”) and the Omnibus Budget Reconciliation Act (OBRA) of 1990 –

changed the requirements and standards for Medigap policies, including standardizing benefits, limiting the

duration of exclusions for pre-existing conditions, and requiring minimum medical loss ratios.3,4 As a result,

today Medicare beneficiaries can enroll in one of 10 plan types, and all plans of the same letter are required to

offer the same benefit package, facilitating an “apples-to-apples” comparison (Table A2).5 Two Medigap plans

– C and F – cover both the Part A and the Part B deductible, thus providing “first-dollar” coverage for all

Medicare-covered services.6

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Medigap Reform: Setting the Context for Understanding Recent Proposals 3

ENROLLMENT IN MEDIGAP PLANS

Enrollment in Medigap has been relatively stable since 2006, despite the rising enrollment in Medicare

Advantage plans during this time frame.7 In 2010, nearly one in four (23%) Medicare beneficiaries nationwide

had a Medigap policy.8 Beneficiary characteristics are drawn from the Medicare Current Beneficiary Survey

Cost and Use File and plan enrollment is from the National Association of Insurance Commissioners (NAIC).

ALL MEDIGAP PLANS

The share of beneficiaries with a Medigap

policy varies across states, ranging from 2

percent of beneficiaries in Hawaii to half

of all beneficiaries in North Dakota

(Exhibit 2; Table A3). Penetration was

highest in the Midwest and Plains states;

nearly half of all beneficiaries in five

states had a Medigap policy to

supplement Medicare in 2010 (IA, KS,

ND, NE, and SD). A larger share of

beneficiaries who purchase Medigap

policies than others on Medicare live in

rural areas (28% versus 23%) and are in

relatively good health (82% versus 73%).

About 4 million beneficiaries with a

Medigap policy also have other forms of

supplemental coverage, including more

than 2 million with employer-sponsored

coverage (Exhibit 1).

The vast majority of individuals with

Medigap (86%) have incomes below

$40,000, and nearly half (47%) have

incomes below $20,000 (Exhibit 3). A

smaller share of Medigap policyholders

than beneficiaries with employer-

sponsored coverage have incomes above

$40,000 and a smaller share of Medigap

policyholders than beneficiaries with Medicaid have incomes below $20,000.

Younger Medicare beneficiaries with disabilities are less likely than seniors to have Medigap because

federal law does not require insurance companies to offer Medigap plans to disabled beneficiaries and

because many beneficiaries who are under the age of 65 and disabled qualify for Medicaid to

supplement Medicare; however, some states have open enrollment periods with guaranteed issue

requirements for beneficiaries under the age of 65 with disabilities.9

Exhibit 2

NOTE: Analysis excludes California, as the majority of health insurers do not report their data to the NAIC. Analysis includes standardized plans A-N, policies existing prior to federal standardization, plans in Massachusetts, Minnesota, and Wisconsin that are not part of the federal standardization program, and plans that identified as Medicare Select; excludes plans where number of covered lives was less than 20. Number of Medigap policyholders as of December 31, 2010, as reported in the NAIC data.SOURCE: K. Desmond, T. Rice, and Kaiser Family Foundation analysis of 2010 National Association of Insurance Commissioners (NAIC) Medicare Supplement data. Kaiser Family foundation and Mathematica Policy Research analysis of CMS State/County Market Penetration Files.

Percent of Medicare Beneficiaries with Medigap by State, All Plans, 2010

National Average = 23%

25%12%

19% 29%

N/A17%

27%

22%

DC 9%

19%

20%

2%

24%

33% 29%

49%

46% 22%

17%

28%

21%

20%

22%

21%

25%

27%

30%

47%13%

30%

26%

13%

12%

25%

51%

19%

24%

16%

27%19%

22%

50%

16%

19%

15%

35%

24%

21%

17%

26%

38%

0%-15% 16%-20% 21%-25% 26%-30% 31%-40% More than 40%(6 states, DC) (12 states) (13 states) (10 states) (3 states) (5 states)

Exhibit 3

17%7% 5%

17%

53%

12%

37%

39%

27%

42%

41%

44%

32%39%

43%

31%

5%

30%

15% 14%25%

11%1%

14%

All MedicareBeneficiaries

MedigapPolicyholders

Employer MedicareAdvantage

Medicaid No supp Cov

$40,000 or more

$20,000-$40,000

$10,000-$20,000

Less than $10,000

NOTE: Numbers do not sum due to rounding.SOURCE: Kaiser Family Foundation analysis of the CMS Medicare Current Beneficiary Survey Cost and Use File, 2010.

Distribution of Income of Medicare Beneficiaries, by Source of Supplemental Coverage, 2010

Page 4: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

Medigap Reform: Setting the Context for Understanding Recent Proposals 4

MEDIGAP PLANS WITH FIRST-DOLLAR COVERAGE

Nationwide, about 12 percent of Medicare

beneficiaries had plans C or F in 2010,

plans with first-dollar coverage that

covers both the Part A and Part B

deductibles. The share of Medicare

beneficiaries with Medigap plans C or F

varies greatly by state (Exhibit 4). In 5

states, more than one-third of Medicare

beneficiaries had Medigap plans C or F

(IA, KS, ND, NE and SD), while in 4

states, less than 2 percent of beneficiaries

had Medigap plans C or F (HI, MA, MN

and WI).10

The majority of people with Medigap

(54%) had first-dollar coverage with

either plan C or plan F in 2010 (13% and

40%, respectively; Exhibit 5). A small

share (8%) of people with Medigap were

in pre-standardized plans that were

issued prior to the federal

standardization of Medigap in 1992.

Another eight percent are in plan J,

which is no longer available to new

policyholders and included prescription

drug coverage prior to the inception of

the Medicare Part D prescription drug

program in 2006. Plans M and N, established in June 2010, had more than 144,000 policyholders by

the end of 2010.

The share of Medigap policyholders with plans C or F varies by state (Table A3). In 26 states, more

than half of the people with Medigap had plan F. In another two states, Rhode Island and Michigan,

more than half of the people with Medigap had plan C.

Exhibit 4

SOURCE: K. Desmond, T. Rice, and Kaiser Family Foundation analysis of 2010 National Association of Insurance Commissioners (NAIC) Medicare Supplement data.

Share of Medicare Beneficiaries withMedigap Plans C and F, 2010

National Average = 12%

EXHIBIT 4

5%DC

3%8%

14% 6%

N/A12%

12%

8%

8%

13%

1%

18%

19% 18%

37%

39% 10%

10%

20%

13%

<1%<1%

18%

18%

21%

34%9%

8%

13%

8%

6%

11%

46%

11%

15%

12%

15%

17%

13%

36%

10%

11%

9%

13%

15%

12%

10%

29%

<1%16%

0%-5% 6%-10% 11%-15% 16%-20% 21%-30% More than 30%(5 states, DC) (13 states) (16 states) (8 states) (2 states) (5 states)

Exhibit 5

Plan A2% Plan B

3%

Plan C13%

Plan D3%

Plan E1%

Plan F40%

Plan G3%

Plan J8%

Plan N2%

Plans H, I, K, L, MEach 1% or less

PreStandardization8%

MA, MN, and WI4%

SELECT9%

Share of Medigap Policyholders by All Plan Types, 2010

Total Number of Medigap Policyholders, 2010= 9.3 million

NOTE: Analysis excludes California, as the majority of health insurers do not report their data to the NAIC. Analysis includes standardized plans A-N, policies existing prior to federal standardization (PreStandardization), and plans in Massachusetts, Minnesota, and Wisconsin that are not part of the federal standardization program; includes plans that identified as Medicare Select; excludes plans where number of covered lives was less than 20. Number of Medigap policyholders as of December 31, 2010, as reported in the NAIC data.SOURCE: K. Desmond, T. Rice, and Kaiser Family Foundation analysis of 2010 National Association of Insurance Commissioners (NAIC) Medicare Supplement data.

Page 5: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

Medigap Reform: Setting the Context for Understanding Recent Proposals 5

PREMIUMS FOR MEDIGAP PLANS

Beneficiaries with Medigap generally pay a

monthly premium for their coverage, in addition

to their Medicare premiums (Part B and D).11

People with Medigap paid an average of $183 per

month in premiums for their policy in 2010, with

wide variations across states and by plan type

(Table A3). Even when ignoring the least

expensive (in the bottom decile) and most

expensive (in the top decile) states, average

premiums can vary by as much as $79 per month

across states for the same plan, despite a

standardized benefit package (Exhibit 6). For

example, the average plan F premium across all

states is $181 per month. Average plan F

premiums range from a low of $129 per month in

Vermont, to a high of $226 per month in

neighboring New York (Exhibit 7); both

Vermont and New York require premiums to be

community rated, indicating that states’ rating

rules do not seem to exclusively determine

whether states’ average premiums are relatively

low or high.12 In 80 percent of states, the

average monthly premium for plan F was

between $155 and $197. Similarly, average plan

C premiums nationwide are $177 per month, and

in most states, the average monthly premium for

Plan C was between $161 and $213 (Table A3).

Exhibit 6

$140

$169 $177

$187 $175

$181 $169

$186 $196 $195

A B C D E F G H I J

NOTE: Analysis excludes California, as the majority of health insurers do not report their data to the NAIC. Analysis includes standardized plans A-J; excludes plans K-L because of the small number of policyholders enrolled in these plans; excludes policies existing prior to federal standardization; excludes plans in Massachusetts, Minnesota, and Wisconsin; excludes plans that identified as Medicare Select; excludes plans where number of covered lives was less than 20.SOURCE: K. Desmond, T. Rice, and Kaiser Family Foundation analysis of 2008-2009 National Association of Insurance Commissioners (NAIC) Medicare Supplement data.

Distribution of Monthly Medigap Premiums, Plans A – J, 2010

90th

percentile

National average

premium

10th

percentile

10th percentile $89 $130 $161 $149 $145 $155 $140 $149 $151 $157

90th percentile $168 $198 $213 $205 $206 $197 $195 $208 $215 $211

Exhibit 7

National Average = $181

NOTE: Analysis excludes California, as the majority of health insurers do not report their data to the NAIC. Analysis includes standardized plan F; excludes plans that identified as Medicare Select; excludes plans where number of covered lives was less than 20.SOURCE: K. Desmond, T. Rice, and Kaiser Family Foundation analysis of 2008-2009 National Association of Insurance Commissioners (NAIC) Medicare Supplement data.

Average Monthly Medigap Premiums for Plan F, by State, 2010

$174$158

$166 $163

N/A$181

$183

$184

DC $180

$209

$173

$139

$176

$193 $186

$176

$174 $177

$189

$156

$209

$201

$175

$155

$177

$178

$172

$189$181

$183

$220

$165

$226

$162

$154

$178

$171

$154

$163

$171

$173

$178

$168

$190

$178

$129

$158

$172

$171

$174

$162

Less than $150 $151-$160 $161-$170 $171-$180 $181-$190 More than $190(2 states) (6 states) (7 states) (19 states, DC) (9 states) (6 states)

Page 6: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

Medigap Reform: Setting the Context for Understanding Recent Proposals 6

OVERVIEW OF RECENT PROPOSALS TO MODIFY MEDIGAP

COVERAGE

Various proposals and recommendations have emerged in recent years that would restrict, limit and/or

penalize Medigap coverage, generally in the context of broader proposals to reduce federal spending (Table

1).13 These proposals and recommendations to change Medigap coverage are often motivated by several

studies that find most Medicare beneficiaries with Medigap use more Medicare-covered services and incur

higher Medicare costs than beneficiaries without supplemental coverage.14 For example, a study from the

Medicare Payment Advisory Commission (MedPAC) showed that spending for Medicare beneficiaries with

Medigap policies was 33 percent higher than for beneficiaries without supplemental coverage.15 Researchers

have also found that health care spending grew at a faster rate for beneficiaries with Medigap than for

beneficiaries in traditional Medicare with no supplemental coverage.16 These studies are consistent with

numerous studies that show individuals use fewer services – both necessary and unnecessary – when

confronted with larger cost-sharing requirements.17

Prohibiting first-dollar Medigap coverage is therefore projected to reduce total Medicare spending and

beneficiary spending, because exposure to higher cost-sharing requirements would lead enrollees to use fewer

health care services.18 Requiring beneficiaries to pay higher cost-sharing, however, could also lead to higher

aggregate spending over the long term for some vulnerable subpopulations, such as the chronically ill,

beneficiaries dually eligible for Medicare and Medicaid, and low-income seniors, if they forgo necessary

services as a result, and use more high-cost, acute care services in the future.19

Many proposals and recommendations would prohibit Medigap plans from providing first-dollar coverage by

requiring plans to include deductibles for Part A and Part B services. Such proposals are designed to

discourage utilization (and reduce spending) by exposing beneficiaries to greater costs when they seek medical

care. The Congressional Budget Office (CBO) estimated in its 2013 report Options for Reducing the Deficit:

2014 to 2023 that barring Medigap policies from paying the first $550 in cost-sharing liability and limiting

coverage to 50 percent of the next $4,950 in out-of-pocket costs could achieve $58 billion in savings from 2015

to 2023.20 Under this approach, beneficiaries with Medigap could be expected to use fewer Medicare-covered

services due to higher cost-sharing requirements, which would lead to a decrease in both average Medigap

premiums and Medicare Part B premiums. Analyses have found that most Medicare beneficiaries with

Medigap policies would be expected to pay less for their health care overall, but enrollees in relatively poor

health would be more likely to face higher overall health care costs.21

Other proposals would apply a premium surcharge (or excise tax) on Medigap premiums. For example,

President Obama’s budget for fiscal year (FY) 2014 proposed applying a surcharge on Part B premiums that

would be equivalent to about 15 percent of the average Medigap premium on new beneficiaries that purchase

Medigap policies with “particularly low cost-sharing requirements,” beginning in 2017.22 The Office of

Management and Budget (OMB) estimated that this proposal would save approximately $2.9 billion between

2017 and 2023, or approximately $7 billion over 10 years. The CBO estimated in its 2008 report Budget

Options, Volume 1: Health Care that imposing a 5 percent excise tax on all Medigap insurers could achieve

savings of about $12.1 billion over ten years.23 In general, this approach is designed to discourage the purchase

of Medigap policies, but may not have much of an effect on utilization or spending for individuals who choose

to purchase a policy with the added fee.

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Medigap Reform: Setting the Context for Understanding Recent Proposals 7

Table 1. Comparison of Recent Medigap Proposals and Recommendations

Date Introduced Proposal Authors Medigap Provision April 29, 2013 Brookings Institution,

Engelberg Center for Health Care Reform

Would require Medigap plans to have an actuarially-equivalent co-pay of at least 10 percent.

April 18, 2013 Bipartisan Policy Center

Would require Medigap plans to include a deductible of at least $250, cover no more than 50 percent of beneficiaries’ copayments and coinsurance, and provide an out-of-pocket limit no lower than $2,500, beginning in 2016.

April 10, 2013 President’s FY2014 Budget

Would introduce a surcharge on Part B premiums that would be equivalent to about 15 percent of the average Medigap premium for new beneficiaries that purchase Medigap policies with “particularly low cost-sharing requirements,” beginning in 2017. Current beneficiaries, and individuals who become eligible for Medicare prior to 2017, would not be subject to the premium surcharge.

February 26, 2013 Brookings Institution, The Hamilton Project24

Would apply an excise tax of up to 45 percent on Medigap plan premiums.

February 19, 2013 Erskine Bowles and Former Sen. Alan Simpson

Would prohibit Medigap and TRICARE for Life plans from covering the Medicare deductible and no more than 50 percent of the base coinsurance, up to the initial limit; in the interim, would apply a surcharge to the Part B premium of Medigap plans.

January 24, 2013 Sen. Orrin Hatch Would limit Medigap plans from providing first-dollar coverage for cost-sharing.

December 17, 2012 Joseph Antos Would change Medigap plans so that policyholders are sensitive to the cost of their medical care. Would modify rules to require insurers to offer Medigap coverage whenever beneficiaries apply for it.

December 12, 2012 Sen. Bob Corker, S. 3673

Would require the NAIC to review and revise the Medigap benefit packages to allow for revised benefit packages to be implemented by January 1, 2015. Revised plans would be prohibited from covering the unified deductible and more than 50 percent of the cost-sharing after the unified deductible. Medigap policies could not be issued after December 31, 2016 to beneficiaries who previously were not covered by a Medigap policy.

November 13, 2012 Center for American Progress

Would prohibit Medigap plans from covering the first $500 of beneficiaries’ cost-sharing for beneficiaries with incomes above 400 percent of the federal poverty level, with exemptions for primary care and care for chronic disease.

June 2012 Medicare Payment Advisory Commission (MedPAC)

Recommended applying a surcharge on Medigap plans and other supplemental insurance.

March 15, 2012 Sens. Rand Paul, Lindsey Graham, Mike Lee, and Jim DeMint

Would prohibit all Medigap policies as of January 1, 2014.

February 16,2012 Sens. Richard Burr and Tom Coburn

Would prohibit Medigap plans from covering the first $500 of beneficiaries’ cost-sharing and limit coverage above $500 to 50 percent of the next $5,000 of Medicare cost-sharing.

Source: Kaiser Family Foundation, “Medicare and the Federal Budget: Comparison of Medicare Provisions in

Recent Federal Debt and Deficit Reduction Proposals,” October 2013.

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Medigap Reform: Setting the Context for Understanding Recent Proposals 8

DISCUSSION

Almost since the Medicare program’s inception, Medigap policies have been an important source of

supplemental insurance for beneficiaries due to Medicare’s relatively high cost-sharing requirements and

significant gaps in coverage. Almost one in four (23%) beneficiaries rely on Medigap to supplement their

Medicare coverage, half of whom enroll in plans C or F that provide first-dollar coverage. About half of

beneficiaries in five states have Medigap as a source of supplemental insurance; in these same five states, one-

third of all beneficiaries have elected plans C or F, which provide first-dollar coverage. Medigap policies help to

shield beneficiaries from sudden, out-of-pocket costs, allow beneficiaries to more accurately budget their

health care expenses, and minimize the paperwork burden for beneficiaries.

Some policymakers have proposed changes to Medigap in the context of broader efforts to reduce federal

spending. Some proposals would prohibit Medigap plans from providing first-dollar coverage, while other

proposals would apply a premium surcharge on Medigap premiums to discourage the purchase of the policies.

Often these proposals are motivated by studies that find most Medicare beneficiaries with Medigap use more

Medicare-covered services and incur higher Medicare costs than beneficiaries without supplemental coverage.

Exposing Medigap enrollees to higher cost-sharing, by either prohibiting first-dollar coverage or discouraging

the purchase of Medigap policies through a surcharge, is projected to reduce total Medicare spending and

beneficiary spending, because studies show that individuals use fewer services when confronted with larger

cost-sharing requirements. However, for some vulnerable populations, requiring beneficiaries to pay higher

cost-sharing could increase spending over the long term, if they forgo necessary services and as a result use

more high-cost, acute care services in the future.

Whether a premium surcharge or a prohibition on first-dollar coverage, such policies could have a

disproportionate effect on middle-income beneficiaries who are not poor enough for Medicaid, nor have access

to employer-sponsored retiree health care. Either policy could also have a disproportionate effect on

beneficiaries in Midwest and Plain states with relatively high Medigap enrollment. Striking a balance between

the goals of achieving savings, without imposing financial barriers to care, will be challenging as policymakers

grapple with the dual issues of rising program costs and the national debt.

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Medigap Reform: Setting the Context for Understanding Recent Proposals 9

ENDNOTES

1 See Testimony of Patricia Neuman, “Rethinking Medicare’s Benefit Design: Opportunities and Challenges,” U.S. Congress, House Energy and Commerce Committee, Subcommittee on Health, June 26, 2013.

2 This brief updates prior work that used earlier years of data. See Kaiser Family Foundation, “Medigap Reform: Setting the Context,” September 2011.

3 Plans in Massachusetts, Minnesota, and Wisconsin were not part of the federal standardization program. All existing Medigap policies in the other states were grandfathered, and could continue to not conform to the standard federal benefit packages.

4 Rice, T., M.L. Graham, and P.D. Fox. 1997. "The Impact of Policy Standardization on the Medigap Market." Inquiry 34(2): 106-116. 5 For a more thorough history of the federal involvement in the Medigap market, see Kaiser Family Foundation, “Medigap: Spotlight on Enrollment, Premiums, and Recent Trends,” April 2013.

6 Plan F also covers extra charges incurred by beneficiaries seeing physicians who do not accept assignment.

7 Kaiser Family Foundation, “Medigap: Spotlight on Enrollment, Premiums, and Recent Trends,” April 2013.

8 In this analysis, estimates of Medigap enrollment are based upon total covered lives reported as of December 31 of each year, and represent a snapshot of enrollment at that time.

9 Some states have open enrollment periods with guaranteed issue requirements for beneficiaries under the age of 65 with disabilities. For details see Kaiser Family Foundation, “Medigap: Spotlight on Enrollment, Premiums, and Recent Trends,” April 2013.

10 Plans in Massachusetts, Minnesota, and Wisconsin were grandfathered and were not part of the federal standardization program.

11 Premium data is from the NAIC in 2010.

12 In 2013, eight states (AR, CT, MA, ME, MN, NY, VT, and WA) required Medigap premiums to be community rated, four states (AZ, FL, GA, and ID) required premiums to be issue age rated (and permitted community rating), and 38 states and the District of Columbia allowed attained age rating for premiums.

13 Other policy options are also described in Kaiser Family Foundation, “Policy Options to Sustain Medicare for the Future,” January 2013.

14 Lemieux, J., T. Chovan, K. Heath. 2008. “Medigap Coverage and Medicare Spending: A Second Look.” Health Affairs 27(2): 469-477.

15 Hogan, C. 2009. Exploring the effects of secondary coverage on Medicare spending for the elderly. Washington, DC: Contractor report for MedPAC. 16 Golberstein, E., K. Walsh, Y. He, and M.E. Chernew. 2012. “Supplemental Coverage Associated With More Rapid Spending Growth For Medicare Beneficiaries.” Health Affairs 32(5): 873-881.

17 For a review of the literature, see Swartz, K. December 2010. “Cost-sharing: Effects On Spending and Outcomes.” Robert Wood Johnson Foundation, Research Synthesis Report No. 20. Also see, Medicare Payment Advisory Commission (MedPAC), Report to Congress: Aligning Incentives in Medicare, June 2010. See also Lohr, K.N., R.H. Brook, C.J. Kamberg, et al. 1986. “Effect of Cost Sharing on Use of Medically Effective and Less Effective Care.” Medical Care 24(9, Supplement): S31-S38.

18 Kaiser Family Foundation, “Medigap Reforms: Potential Effects of Benefit Restrictions on Medicare Spending and Beneficiary Costs,” July 2011.

19 Capps C. and D. Dranove. “Intended and Unintended Consequences of a Prohibition on Medigap First-Dollar Benefits,” for America’s Health Insurance Plans, October 2011. Similarly, the NAIC has argued that focusing on Medigap as the driver of medical care use discourages the use of all care, in contrast to other reforms that would aim to incentivize the use of necessary and appropriate care. See National Association of Insurance Commissioners, Senior Issues Task Force, Medigap PPACA Subgroup, “Medicare Supplement Insurance First-Dollar Coverage and Cost Shares Discussion Paper,” October 31, 2011.

20 The CBO analyzed a proposal that would bar Medigap policies from paying the first $550 in cost-sharing liability and limit coverage to 50 percent of the next $4,950 before the plan could cover 100 percent of beneficiaries’ out-of-pocket costs. The cost estimate assumed no beneficiaries were grandfathered and amounts were indexed to increase at the same rate as per capita traditional Medicare spending. See Congressional Budget Office (CBO), Options for Reducing the Deficit: 2014 to 2023, November 2013.

21 Kaiser Family Foundation, “Medigap Reforms: Potential Effects of Benefit Restrictions on Medicare Spending and Beneficiary Costs,” July 2011.

22 Office of Management and Budget, “Fiscal Year 2014 Budget of the U.S. Government,” April 10, 2013.

23 Congressional Budget Office (CBO), Budget Options Volume I: Health Care, December 2008.

24 This proposal was authored by Jonathan Gruber.

Page 10: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

Medigap Reform: Setting the Context for Understanding Recent Proposals 10

Table A1. Medicare Benefits and Cost-Sharing Requirements, 2014

Part A

Premium None for most beneficiaries (up to $426 for some)

Deductible $1,216 per benefit period

Inpatient hospital Days 1-60: no coinsurance; days 61-90: $304/day; days 91-150: $608/day; days after 150: no coverage

Skilled nursing facility Days 1-20: no coinsurance; days 21-100: $152/day; days after 100: no coverage

Home health No coinsurance

Hospice No coinsurance

Inpatient psychiatric hospital Same as inpatient hospital stay (up to 190 days in a lifetime)

Out-of-pocket spending limit None

Part B

Premium $104.90/month (higher for those with higher incomes)

Deductible $147

Physician and other medical services (such as ambulatory surgical services)

20% coinsurance

Clinical laboratory services No coinsurance

Home health care No coinsurance

Outpatient mental health services 20% coinsurance

One-time "Welcome to Medicare" physical exam and annual “Wellness” visit

No coinsurance

Preventive services No coinsurance for most services (although 20% coinsurance for some). Some limitations based on frequency, type of service, and patient’s age and medical history.

Out-of-pocket spending limit None

Part D

Information below applies to the standard Part D benefit; benefits and cost-sharing requirements typically vary across plans. Beneficiaries receiving low-income subsidies pay reduced cost-sharing amounts

Premium $32.42 national average monthly premium (unweighted PDP and MA-PD plan average). Higher-income enrollees required to pay a monthly surcharge.

Deductible $310

Initial coverage (up to $2,850 in total drug costs)

25% coinsurance

Coverage gap (between $2,850 and $6,691 in total drug costs)

47.5% coinsurance for brand-name drugs, 72% coinsurance for generic drugs (phasing down to 25% for both brand and generic drugs by 2020)

Catastrophic coverage (above $4,550 in out-of-pocket spending)

Minimum of $2.55/generic, $6.35/brand; or 5% coinsurance

NOTE: This table does not include all Medicare-covered benefits or preventive services; for a complete listing, see http://www.medicare.gov/Coverage/Home.asp and http://www.medicare.gov/Health/Overview.asp.

SOURCE: CMS, www.medicare.gov, Medicare & You 2014, Your Guide to Medicare’s Preventive Services.

Page 11: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

Medigap Reform: Setting the Context for Understanding Recent Proposals 11

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Page 12: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

Medigap Reform: Setting the Context for Understanding Recent Proposals 12

TAB

LE A

3. S

har

e o

f M

edic

are

Ben

efic

iari

es w

ith

Med

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, an

d A

vera

ge M

edig

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rem

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s, B

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8%54

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164

$

158

$

163

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zon

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184

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8

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$

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6

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Page 13: policy as a supplemental source of coverage in 2010 Nearly ......The structure of Medigap policies has become more uniform and regulated over the years to help beneficiaries more easily

The Henry J. Kaiser Family Foundation Headquarters: 2400 Sand Hill Road, Menlo Park, CA 94025 | Phone 650-854-9400 | Fax 650-854-4800 Washington Offices and Barbara Jordan Conference Center: 1330 G Street, NW, Washington, DC 20005 | Phone 202-347-5270 | Fax 202-347-5274 | www.kff.org The Kaiser Family Foundation, a leader in health policy analysis, health journalism and communication, is dedicated to filling the need for trusted, independent information on the major health issues facing our nation and its people. The Foundation is a non-profit private operating foundation, based in Menlo Park, California.

Nebraska

129,723

         

47%

4%69%

27%

$202

 $

189

 $

197

 

Nevada

46,390

           

13%

6%59%

36%

$196

 $

181

 $

189

 

New Ham

pshire

65,632

           

30%

6%22%

73%

$204

 $

183

 $

182

 

New Jersey

341,520

         

26%

31%

20%

49%

$218

 $

220

 $

203

 

New Mexico

39,945

           

13%

7%56%

36%

$158

 $

165

 $

153

 

New York

356,360

         

12%

12%

40%

48%

$214

 $

226

 $

204

 

North Carolina

362,909

         

25%

7%36%

57%

$204

 $

162

 $

194

 

North Dakota

54,716

           

51%

2%88%

9%$

169

 $

154

 $

162

 

Ohio

355,533

         

19%

26%

32%

42%

$201

 $

178

 $

183

 

Oklahoma

144,292

         

24%

4%59%

36%

$182

 $

171

 $

172

 

Oregon

98,482

           

16%

6%69%

25%

$174

 $

154

 $

161

 

Pennsylvania

606,288

         

27%

47%

9%44%

$143

 $

163

 $

139

 

Rhode Island

34,180

           

19%

76%

14%

10%

$168

 $

171

 $

173

 

South Carolina

170,556

         

22%

5%52%

43%

$184

 $

173

 $

168

 

South Dakota

67,191

           

50%

2%70%

28%

$177

 $

178

 $

185

 

Tennessee

166,518

         

16%

11%

50%

39%

$196

 $

168

 $

166

 

Texas

566,289

         

19%

5%54%

41%

$213

 $

190

 $

196

 

Utah

42,323

           

15%

9%49%

42%

$189

 $

178

 $

162

 

Verm

ont

38,157

           

35%

35%

3%62%

$167

 $

129

 $

144

 

Virginia

265,844

         

24%

6%56%

38%

$190

 $

158

 $

201

 

Washington

199,318

         

21%

8%51%

41%

$172

 $

172

 $

191

 

West Virginia

64,200

           

17%

11%

48%

41%

$183

 $

171

 $

199

 

Wisconsin

233,396

         

26%

0%0%

100%

$178

 $

174

 $

191

 

Wyoming

29,997

           

38%

8%68%

23%

$167

 $

162

 $

164

 

US Total

9,290,144

     

23%

13%

40%

46%

$177

 $

181

 $

182

 

Plan F

Share of Medigap

 policyholders

Average

 Premium, 

weighted by enrollment

State

NOTE:  Excludes Ca

lifornia, as the m

ajority of health insurers do not report their data to the NAIC.  Numbers m

ay not sum to 100

 percent due to rounding.  

Analysis includes standardized plans A‐N, p

olicies existing prior to federal standardization, and plans in M

assa

chuse

tts, M

innesota, and W

isconsin that are 

not part of the federal standardization program; does not include companies and plans that identified as Medicare Select;  excludes companies and plans 

where number of covered lives was less

 than 20. 

SOURCE:  K. Desmond, T. R

ice, and Kaiser Fa

mily Fo

undation analysis of 2010 National Association of Insurance

 Commissioners (NAIC) Medicare Supplement 

data. 

First Dollar Coverage

First Dollar Coverage

Other 

Medigap

 

Plans

Other 

Medigap

 

Plans

Medigap

 

Policyholders, 

2010

Share of 

Medicare 

beneficiaries 

with M

edigap

 

policy

Plan C

Plan F

Plan C