I certainly think they could make changes to the presentation on Healthcare.gov to limit the effectiveness of silver spamming. They could group all offering of a single issuer together and highlight their benchmark (lowest) price, and require a user to click to expand and see all offered policies. This would at least prevent anti-competitive practices by multiple issuers on the first page of results, regardless of who offered the 10 lowest price plans.
However, given that this NBPP has removed the standardized plan requirement it does not seem like they are interested in regulating this through the website.
With ARPA subsidies having expired, I would expect the non-utilizers to shift to Bronze plans (or Gold in states with mandated metal relativities) rather than stick to Silver CSR plans. As such, wouldn't a bigger risk be of Bronze Spamming rather than Silver Spamming? This strategy does hurt on the risk adjustment side since Bronze will have the worst AV and IDF factors for non-utilizers, but it still seems the most straightforward way to scoop up healthy membership heavily leveraged on price.
That is an excellent observation Matthew. I think this rate filing season it will be interesting to see how issuers with a history of this type of strategy approach their rate and offering portfolio. If their main motivation is to be the provider of free to the member plans then they may try to establish the lowest and benchmark silver price and then make sure they have the 10ish lowest price bronze plans that will push their free plans to the top of the page and the others to page 2.
Great piece. Do you think that http://healthcare.gov could make product improvements to prevent silver spamming?
I certainly think they could make changes to the presentation on Healthcare.gov to limit the effectiveness of silver spamming. They could group all offering of a single issuer together and highlight their benchmark (lowest) price, and require a user to click to expand and see all offered policies. This would at least prevent anti-competitive practices by multiple issuers on the first page of results, regardless of who offered the 10 lowest price plans.
However, given that this NBPP has removed the standardized plan requirement it does not seem like they are interested in regulating this through the website.
With ARPA subsidies having expired, I would expect the non-utilizers to shift to Bronze plans (or Gold in states with mandated metal relativities) rather than stick to Silver CSR plans. As such, wouldn't a bigger risk be of Bronze Spamming rather than Silver Spamming? This strategy does hurt on the risk adjustment side since Bronze will have the worst AV and IDF factors for non-utilizers, but it still seems the most straightforward way to scoop up healthy membership heavily leveraged on price.
That is an excellent observation Matthew. I think this rate filing season it will be interesting to see how issuers with a history of this type of strategy approach their rate and offering portfolio. If their main motivation is to be the provider of free to the member plans then they may try to establish the lowest and benchmark silver price and then make sure they have the 10ish lowest price bronze plans that will push their free plans to the top of the page and the others to page 2.