{"id":3718,"date":"2016-08-08T09:00:45","date_gmt":"2016-08-08T16:00:45","guid":{"rendered":"http:\/\/evergreensmallbusiness.com\/?p=3718"},"modified":"2016-08-04T14:27:52","modified_gmt":"2016-08-04T21:27:52","slug":"nervous-washingtons-shop-exchange","status":"publish","type":"post","link":"https:\/\/evergreensmallbusiness.com\/nervous-washingtons-shop-exchange\/","title":{"rendered":"Why You Should Be Nervous About Washington\u2019s SHOP Exchange"},"content":{"rendered":"<p><a href=\"http:\/\/evergreensmallbusiness.com\/wp-content\/uploads\/2016\/08\/man_on_wire.jpg\"><img loading=\"lazy\" decoding=\"async\" class=\"alignleft size-medium wp-image-3721\" src=\"http:\/\/evergreensmallbusiness.com\/wp-content\/uploads\/2016\/08\/man_on_wire-300x241.jpg\" alt=\"A man balances on a tight rope over a city skyline.\" width=\"300\" height=\"241\" srcset=\"https:\/\/evergreensmallbusiness.com\/wp-content\/uploads\/2016\/08\/man_on_wire-300x241.jpg 300w, https:\/\/evergreensmallbusiness.com\/wp-content\/uploads\/2016\/08\/man_on_wire-768x616.jpg 768w, https:\/\/evergreensmallbusiness.com\/wp-content\/uploads\/2016\/08\/man_on_wire-622x499.jpg 622w, https:\/\/evergreensmallbusiness.com\/wp-content\/uploads\/2016\/08\/man_on_wire.jpg 773w\" sizes=\"auto, (max-width: 300px) 100vw, 300px\" \/><\/a>If you\u2019re a small business owner, you should probably be nervous about Washington\u2019s SHOP Exchange.<\/p>\n<p>To start, though, let\u2019s clarify: we\u2019re not talking about the individual exchange. Washington State\u2019s individual exchange really works quite well, despite what many may think given the initial disaster that was Healthcare.gov.<\/p>\n<p>We\u2019re talking about the small business side of the Exchange, <a href=\"http:\/\/evergreensmallbusiness.com\/wa-healthplanfinder-business-update-2017\/\">where things have not been going so well<\/a>. And several reasons justify nervousness\u2026<\/p>\n<h2>Reason #1: Difficulty Getting Insurers to Bite<\/h2>\n<p>A first reason? Too few insurers are participating.<\/p>\n<p>In 2017, for example, most counties in Washington State won\u2019t even be served by the small business side of the Exchange.<\/p>\n<p>This is because UnitedHealthcare is exiting the Exchange, and up until now UnitedHealthcare was the only small business insurer the Exchange had for most counties (Clark and Cowlitz being the exception).<\/p>\n<p>I\u2019ve asked representatives of the Exchange what they attribute this to, and have really only gotten non-answers back like \u201cwell we\u2019re having conversations with carriers\u2026\u201d<\/p>\n<p>Poking around at Exchange <a href=\"http:\/\/www.wahbexchange.org\/wp-content\/uploads\/2015\/12\/HBE_EB_160324_SHOP_Presentation.pdf\">meeting materials that are available publicly on its site<\/a>, it sounds like what might be going on is that there are some major changes to the IT infrastructure of the site before a lot of insurers are willing to give this thing a try (maybe because the site needs to be better to lure more customers?)<\/p>\n<p>Yes, I acknowledge that \u201csounds like what might be happening\u201d is about as speculative as it gets, but until the Exchange leaders become a bit more forthcoming about what\u2019s going on, we don\u2019t really have much to go on.<\/p>\n<p>However, if we\u2019ve deduced correctly that this is the problem, then this is a bigger problem for Washington State small businesses for reasons #2, 3, and 4, which I\u2019ll describe next.<\/p>\n<h2>Reason #2: Lack of Capital Reserves for Big Projects<\/h2>\n<p>Another reason to be nervous? A lack of adequate capital reserves\u2014and a lack of a plan to acquire and maintain adequate capital reserves.<\/p>\n<p>In a <a href=\"http:\/\/www.sao.wa.gov\/state\/Documents\/PA_Health_Benefit_Exch_ar1016997.pdf\">recent state auditor\u2019s report<\/a>, for example, one of the key recommendations for putting the Exchange on a path to sustainability was for the Exchange to establish a long-term financial plan, a working reserve, and a capital reserve.<\/p>\n<p>We should note, for the sake of fairness, that the Exchange is working on this. The Exchange indicated in its response to the state auditor\u2019s report that it has commenced work on establishing a long-term financial plan that includes developing a reserve, and is due to complete this work by December 31<sup>st<\/sup>, 2016. However, any efforts the Exchange makes to implement effective long-term financial planning are hampered by policies of the Legislature described in #3 and 4, below.<\/p>\n<h2>Reason #3: Legislature\u2019s Spending Rules Stop the Exchange from Swiftly Investing in Needed IT Improvements<\/h2>\n<p>A third issue: the lack of support from the Legislature for continuous basic improvement in the information technology required to run a decent exchange. Which sounds crazy.<\/p>\n<p>It is in the Legislature\u2019s best interest to enable the Exchange to make certain improvements to its website as soon as it can, because many of these improvements accelerate the Exchange\u2019s path toward self-sustainability. This is for two main reasons:<\/p>\n<ul>\n<li>Because it improves the customer experience, making it easier for the Exchange to find more customers and thus reducing the Exchange\u2019s per member per month costs, and<\/li>\n<li>Because improvements such as fewer software bugs, better user interfaces, and additional features that allow customers to perform tasks themselves on the website reduce the need for spending on customer support.<\/li>\n<\/ul>\n<p>However, in <a href=\"http:\/\/app.leg.wa.gov\/billinfo\/summary.aspx?bill=1947&amp;year=2013\">HB 1947<\/a> (2013) the Legislature tied the Exchange\u2019s hands when it comes to implementing cost-saving IT improvements. Specifically, the bill states that the Exchange can only spend as much money as the Legislature appropriates to it. In addition, the bill includes a \u201csweeping provision\u201d which states that the Legislature may transfer money from the Exchange\u2019s account to the general account.<\/p>\n<p>To illustrate: for the current biennium (2015-2017), the state budget does not, in fact, simply state that the Legislature will contribute $110 million to the Exchange. Instead, what it states is that the Exchange may not spend more than $110 million. Therefore, even if the Exchange were to successfully apply for a grant elsewhere, that grant would have zero impact on the Exchange\u2019s ability to accelerate investments in IT improvements in the current biennium. Instead, the money would likely be swept into the state\u2019s general fund.<\/p>\n<p>This policy was ostensibly intended as a measure to hold the Exchange more \u201cfiscally responsible.\u201d However, in practice it creates a perverse incentive for the Exchange board to not seek out grant funding as a way to accelerate cost-effective IT improvements. This is because seeking out grants would require considerable effort while providing the exchange with no financial benefit. (I\u2019ve even had representatives of the Exchange tell me that this is their thought process behind why they don\u2019t bother pursuing grants.)<\/p>\n<h2>Reason #4: Legislature\u2019s Sweeping Provision Makes Exchange Finances Unstable<\/h2>\n<p>And then there\u2019s the \u201csweeping\u201d issue, which maybe makes sense for a typical government program but not for an organization with the cash flow uncertainty of the Exchange.<\/p>\n<p>What\u2019s the issue here? Simple. The provision in HB 1947 authorizing \u201cexcess funds\u201d to be removed from the Exchange\u2019s account and placed in the Legislature\u2019s general fund appears to complicate the goal of developing stable reserves. In fact, the auditor\u2019s report specifically asked the Legislature to consider as part of the appropriation process \u201cthe Exchange\u2019s long-term financial plan, its planned list of IT investments, its need for both working and capital reserves, and how <em>sweeping those reserves adversely affects planning<\/em>.\u201d [emphasis added]<\/p>\n<p>It&#8217;s worth emphasizing here that a big part of why this is so important for the Exchange is that both the amount and the timing of the Exchange\u2019s cash inflows are uncertain. The amount is uncertain because much of the Exchange\u2019s revenue comes from a 2% health insurance premium tax and assessments that the Exchange can charge insurers who sell plans through the website\u00a0(almost a bit like a commission, to cover the Exchange\u2019s operating costs).<\/p>\n<p>Timing is uncertain because a large additional portion of the Exchange\u2019s revenue comes from reimbursements from Medicaid for costs the Exchange incurs on Medicaid\u2019s behalf. And, as awkward as this is to point out, according to the state auditor\u2019s report Medicaid has a history of not paying its bills to the Exchange on time.<\/p>\n<p>This is the whole reason the Exchange needs a working reserve (and <a href=\"http:\/\/evergreensmallbusiness.com\/stress-tests-for-your-small-business\/\">why, as small business owners, we need to be thinking about liquidity, too<\/a>). If projected revenues come in a little lower than expected, the Exchange needs some cushion so it knows it can keep the lights on and the servers running. Ditto for if Medicaid pays a bill a few months late. So how nerve-wrecking is it that the Exchange could do the responsible thing by building up an adequate working reserve, only to see the Legislature sweep it all away because some state legislators think that reserve is \u201cexcess funds\u201d?<\/p>\n<h2>Final Thoughts<\/h2>\n<p>These things are all fixable. And to the extent that the Exchange\u2019s leaders have the power to, they seem to be putting a lot of work into trying to fix it.<\/p>\n<p>However, the Legislature still has some things it needs to do if it really wants to get this program working. It needs to change the Exchange\u2019s enacting legislation to remove counterproductive policies such as the appropriations rules and the sweeping provision, and replace these with constructive policies.<\/p>\n<p>Examples of constructive policies the Legislature could enact include:<\/p>\n<ul>\n<li>Requiring the Exchange to have a long-term financial plan that includes provisions for a working reserve and a capital reserve.<\/li>\n<li>Requiring the Exchange to prepare a report for the Legislature explaining why they\u2019ve had such trouble inducing insurers to participate in the small business side of the Exchange, and what their plan is to fix it.<\/li>\n<li>Requiring the Exchange to conduct ongoing user interface studies, including studies of how efficient and intuitive it is for the typical user to work with both the individual and SHOP portions of the website.<\/li>\n<li>Requiring the Exchange to conduct ongoing surveys among Washington residents and small business owners on features they would like to see included as part of both the individual and SHOP portions of the website.<\/li>\n<\/ul>\n<p>We\u2019re keeping up to date on developments with the Washington SHOP Exchange, and will post updates to this blog as they become available. Stay tuned.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>If you\u2019re a small business owner, you should probably be nervous about Washington\u2019s SHOP Exchange. To start, though, let\u2019s clarify: we\u2019re not talking about the individual exchange. Washington State\u2019s individual exchange really works quite well, despite what many may think given the initial disaster that was Healthcare.gov. We\u2019re talking about the small business side of [&hellip;]<\/p>\n","protected":false},"author":3,"featured_media":3721,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_genesis_hide_title":false,"_genesis_hide_breadcrumbs":false,"_genesis_hide_singular_image":false,"_genesis_hide_footer_widgets":false,"_genesis_custom_body_class":"","_genesis_custom_post_class":"","_genesis_layout":"","footnotes":""},"categories":[27,26,9],"tags":[],"class_list":{"0":"post-3718","1":"post","2":"type-post","3":"status-publish","4":"format-standard","5":"has-post-thumbnail","7":"category-health-care","8":"category-insurance","9":"category-software","10":"entry"},"yoast_head":"<!-- This site is optimized with the Yoast SEO Premium plugin v27.3 (Yoast SEO v27.3) - https:\/\/yoast.com\/product\/yoast-seo-premium-wordpress\/ -->\n<title>Why You Should Be Nervous About Washington\u2019s SHOP Exchange - Evergreen Small Business<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/evergreensmallbusiness.com\/nervous-washingtons-shop-exchange\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Why You Should Be Nervous About Washington\u2019s SHOP Exchange\" \/>\n<meta property=\"og:description\" content=\"If you\u2019re a small business owner, you should probably be nervous about Washington\u2019s SHOP Exchange. To start, though, let\u2019s clarify: we\u2019re not talking about the individual exchange. Washington State\u2019s individual exchange really works quite well, despite what many may think given the initial disaster that was Healthcare.gov. 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