A Report on the Actuarial, Marketing, and Legal Analyses
of the CLASS Program
Appendix P: June 22, 2011 Technical Experts Meeting
PDF Version:
http://aspe.hhs.gov/daltcp/reports/2011/class/appP.pdf
(46 PDF pages)
TABLE OF CONTENTS
- APPENDIX Pa: Agenda and Discussion Issues and
Questions
- Agenda
- Issues and Questions
- APPENDIX Pb: Presentation Entitled "Core
Assumptions and Model Outputs"
- APPENDIX Pc: Presentation Entitled "Actuarial
Research Corporation's Long Term Care Insurance Model"
- APPENDIX Pd: Presentation Entitled "The
Avalere Long-Term Care Policy Simulator Model"
- APPENDIX Pe: Presentation Entitled
"Alternative Approaches to CLASS Benefit Design: The CLASS Partnership"
APPENDIX Pa: AGENDA AND DISCUSSION ISSUES AND
QUESTIONS
Technical Expert Panel
Meeting On Actuarial Modeling of the Community Living Assistance
Services and Supports (CLASS) Program
Agenda
June 22, 2011 9:00 am - 3:30 pm
Hubert H. Humphrey Building, Room 705A 200
Independence Avenue, SW Washington, DC 20201
Contact: Marie Belt or Goldwyn Smith
at 202-690-6443 |
9:00 - 9:15 Welcome and Introductions
Ruth Katz
Acting Deputy Assistant Secretary for Disability,
Aging, and Long-Term Care Policy
Kathy Greenlee
Assistant Secretary for
Aging
9:15 - 9:45 Overview of CLASS and Major Modeling Issues
William Marton
Director, Division of Disability and Aging
Policy
Bob Yee
Actuary, CLASS Program Office
9:45 - 10:15 Actuarial Research Corporation (ARC) CLASS Model
John Wilkin
Senior Actuary, ARC
10:15 - 10:45 Questions and Comments on the ARC CLASS Model
10:45 - 11:00 Break
11:00 - 11:30 Avalere Long-Term Care Policy Simulator
(LTC-PS)
Anne Tumlinson
Senior Vice President, Avalere Health
Eric Hammelman
Director, Avalere Health
11:30 - 12:00 Questions and Comments on the Avalere LTC-PS
12:00 - 12:45 Lunch
12:45 - 2:00 Review and Discussion of Core Assumptions and Model
Output
John Wilkin
Senior Actuary, ARC
Eric Hammelman
Director, Avalere Health
2:00 - 2:15 Break
2:15 - 3:30 Presentation and Discussion of Alternative
Approaches
William Marton
Director, Division of Disability and Aging
Policy
Bob Yee
Actuary, CLASS Program Office
3:30 Adjourn
Thank you for your participation on the Technical Expert Panel on
Actuarial Modeling of the Community Living Assistance Services and Supports
(CLASS) Program. The agenda for the meeting is organized around addressing six
major questions (below) and our efforts to develop estimates of premiums,
participation and other important aspects of the CLASS program. Please review
the questions and materials prior to the meeting. After the meeting, we would
very much appreciate it if you could provide follow up comments or thoughts
within a week so that we can incorporate them into our future modeling
efforts.
-
Who is likely to enroll in the CLASS program?
- Do you think that the models approach to adverse selection
is reasonable?
- Can you suggest approaches to validate the models with regards to
their treatment of adverse selection?
- What alternative approaches would you recommend?
-
What is the future long-term care utilization of enrollees likely
to be?
- Do you think that the approach for estimating future claim costs
is reasonable?
- What are the strengths and weaknesses of the survey data that are
the basis for estimating future claim costs?
- What other data could be used to model future claims?
-
Are other key assumptions reasonable?
- Are the interest rate assumptions reasonable (e.g., 4.7%, 5.7%,
6.7% average annual rate of return)?
- Are the annual voluntary lapse assumptions reasonable (e.g., .5%,
.75%, 1% per year)?
- How should the progression of disability among workers be modeled
during their working years and beyond?
- Are the assumptions of morbidity improvement reasonable (.25%,
.5%, .75% per year for 20 years; 0% thereafter)?
- Are the mortality improvement assumptions reasonable (e.g.,
1.31%, .78%, .32% per year)?
-
What level of participation should we expect?
- What are reasonable lower and upper bounds to participation? What
do you think is the best point estimate of participation?
- Do you think the models reasonably reflect the dynamic between
participation and adverse selection?
- How should we model the interaction between program demand and
premium levels?
-
What alternative designs would put the program on stronger
financial footing?
- Other than underwriting and mandatory enrollment, what features
would you suggest to mitigate adverse selection?
- What aspects of the program should be changed to maximize
participation?
-
Other than specific changes to the benefit plan, what strategies
should we pursue to mitigate program risk?
Summary of CLASS |
Program Features |
CLASS Benefit in Statute
|
Enrollment
Requirements: |
|
Age 18+ |
Yes |
Taxable Wages/Income |
Yes |
Actively Employed |
Yes |
Not in Institution |
Yes |
Coverage
Benefits: |
|
Primary Benefit |
Cash |
Daily Benefit Amount (DBA) |
$50
(Average) |
Unit of Payment |
Daily or
Weekly |
Minimum Duration in Years |
NA -
Lifetime |
Total Value |
TBD |
Inflation Protection |
CPI-U |
Advocacy Services |
Yes |
Advice and Asst. Counseling |
Yes |
Eligibility
for Benefits: |
|
5 Year Vesting Period |
Yes |
Work Req. Over Vesting Period |
At Least 3
Years |
Earnings Req. Over Vesting
Period |
$1,120/Year |
24 Months of Prior Prem. Payment |
Yes |
Minimum Benefit Trigger |
2 or 3 of 6
ADLs1 |
Tiered Benefit |
Yes |
Elimination Period in Days |
0 |
Presumptive Eligibility |
Yes - if in
Inst.2 |
Administrative Expenses |
3% |
Monthly
Premium: |
|
Underwritten (Other Than
Age) |
No |
Indexed to Inflation |
No |
Low Income Premium |
Yes |
Full Time Student Premium |
Yes |
Waiver of Premium |
TBD |
Level Premium |
After Age
653 |
Return of Premium |
TBD |
CLASS: Issues for Discussion
- Who is likely to enroll in the CLASS program?
- Modeling adverse selection/antiselection
- Data limitations
- What is the future long-term care utilization of enrollees likely
to be?
- Modeling future claim costs
- Data limitations
- Are other key assumptions reasonable?
- Return on Investment (4.7%, 5.7%, 6.7% average annual rate of
return)
- Lapsation (.5%, .75%, 1% per year)
- Morbidity Improvement (.25%, .5% .75% per year for 20 years; 0%
thereafter)
- Mortality Improvement (1.31%, .78%, .32% per year)
CLASS: Issues for Discussion
- What level of participation should we expect?
- Range of 1% to 4%
- Premium-demand interaction
- What alternative program designs would put the program on stronger
financial footing?
- Minor changes (e.g., higher earnings requirements, indexed
premiums, etc.)
- Major changes (e.g., family of options; phased
enrollment)
- What strategies should we pursue to mitigate program risk?
- Waiver of premium
- Cross-subsidization
- Other strategies?
Summary of CLASS Plans |
Program Features |
CLASS Benefit in
Statute |
Modified |
Enrollment
Requirements: |
|
|
Age 18+ |
Yes |
Yes |
Taxable Wages/Income |
Yes |
Yes |
Actively Employed |
Yes |
Yes |
Not in Institution |
Yes |
Yes |
Coverage
Benefits: |
|
|
Primary Benefit |
Cash |
Cash |
Daily Benefit Amount (DBA) |
$50
(Average) |
$50
(Average) |
Unit of Payment |
Daily or
Weekly |
Daily or
Weekly |
Minimum Duration in Years |
NA -
Lifetime |
NA -
Lifetime |
Total Value |
TBD |
TBD |
Inflation Protection |
CPI-U |
CPI (2.8%) |
Advocacy Services |
Yes |
Yes |
Advice and Asst. Counseling |
Yes |
Yes |
Eligibility
for Benefits: |
|
|
5 Year Vesting Period |
Yes |
Yes |
Work Req. Over Vesting Period |
At Least 3
Years |
5 Years (or 40 Qs)1 |
Earnings Req. Over Vesting Period |
$1,120/Year |
$12,000/Year |
24 Months of Prior Prem.
Payment |
Yes |
Yes |
Minimum Benefit Trigger |
2 or 3 of 6
ADLs2 |
TBD |
Tiered Benefit |
Yes |
Yes |
Elimination Period in Days |
0 |
0 |
Presumptive Eligibility |
Yes - if in
Inst.3 |
Yes - if in
Inst.3 |
Administrative Expenses |
3% |
3% |
Monthly
Premium: |
|
|
Underwritten (Other Than
Age) |
No |
No |
Indexed to Inflation |
No |
Yes
(2.8%) |
Low Income Premium |
Yes |
Yes |
Full Time Student Premium |
Yes |
Yes |
Waiver of Premium |
TBD |
TBD |
Level Premium |
After Age
654 |
After Age
654 |
Return of Premium |
TBD |
TBD |
APPENDIX Pb: PRESENTATION ENTITLED "CORE
ASSUMPTIONS AND MODEL OUTPUTS"
Core Assumptions and Model Outputs
John Wilkin, ARC
Eric Hammelman, Avalere
Health
|
CLASS Benefit in
Statute |
Modified
CLASS |
Enrollment
Requirements |
|
|
Age 18+ |
Yes |
Yes |
Taxable Wages/Income |
Yes |
Yes |
Actively Employed |
Yes |
Yes |
Not in Institution |
Yes |
Yes |
Coverage
Benefits |
|
|
Primary Benefit |
Cash |
Cash |
Daily Benefit Amount (DBA) |
$50
(Average) |
$50
(Average) |
Unit of Payment |
Daily or
Weekly |
Daily or
Weekly |
Minimum Duration in Years |
NA -
Lifetime |
NA -
Lifetime |
Total Value |
TBD |
TBD |
Inflation Protection |
CPI-U |
CPI-U |
Advocacy Services |
Yes |
Yes |
Advice and Asst. Counseling |
Yes |
Yes |
Eligibility
for Benefits |
|
|
5 Year Vesting Period |
Yes |
Yes |
Work Req. Over Vesting Period |
At Least 3
Years |
5 Years (or 40
Qs)* |
Earnings Req. Over Vesting
Period |
$1,120/Year |
$12,000/Year* |
24 Months of Prior Prem. Payment |
Yes |
Yes |
Minimum Benefit Trigger |
2 or 3 of 6
ADLs |
TBD |
Tiered Benefit |
Yes |
Yes |
Elimination Period in Days |
0 |
0 |
Presumptive Eligibility |
Yes - if in
Inst. |
Yes - if in
Inst. |
Administrative Expenses |
3% |
3% |
Monthly
Premium |
|
|
Underwritten (Other Than Age) |
No |
No |
Indexed to Inflation |
No |
Yes (2.8%)* |
Low Income Premium |
Yes |
Yes |
Full Time Student Premium |
Yes |
Yes |
Waiver of Premium |
TBD |
TBD |
Level Premium |
After Age
65 |
After Age
65 |
Return of Premium |
TBD |
TBD |
*
Modified CLASS changes these three options. |
Average Premium for CLASS in Statute vs. CLASS Modified with
Full Waiver of Premium, 2+ ADL trigger, and 2% Participation |
|
CLASS Modeling Assumptions: 3 Scenarios |
Scenario |
I Worse than Expected |
II Expected |
III Better than Expected |
Description |
Antiselection: ARC |
0.85 |
0.70 |
0.55 |
Dampening factor:
1=perfect antiselection |
Antiselection: Avalere |
0.85 |
0.70 |
0.60 |
|
Relative
Claim Costs |
1.2 |
1.1 |
1.0 |
Increased incidence from
survey data |
Return on
Investment |
4.70% |
5.70% |
6.70% |
Average annual rate of
return |
Lapsation |
0.50% |
0.75% |
1.00% |
Percentage lapse per
year |
Morbidity
Improvement |
0.25% |
0.50% |
0.75% |
Annual percentage
improvement for first 20 years; 0% thereafter |
Mortality
Improvement |
1.31% |
0.78% |
0.32% |
Annual percentage
improvement over the 75 year period |
Participation |
1% |
2% |
4% |
|
Average Premium for Scenarios I, II and III Full Waiver
of Premium, 2+ ADL trigger, and 2% Participation |
|
Average Premium for Scenario II by Selection 1% and 4%
Participation with Full Waiver of Premium, 2+ ADL trigger |
|
Average Premium for Scenario II by Claim Costs at 1% and 4%
Participation with Full Waiver of Premium, 2+ ADL
trigger (ARC) |
|
Average Premium for Scenario II by Claim Costs 1% and 4%
Participation with Full Waiver of Premium, 2+ ADL
trigger (Avalere) |
|
Average Premium for Scenario II by Participation
Rate Full Waiver of Premium and 2+ ADL trigger |
|
Average Premium for Scenario II by ADL Trigger Full
Waiver of Premium and 2% Participation |
|
Average Premium for Scenario II by Waiver 2+ ADL Trigger
and 2% Participation |
|
Average Premium by Return on Investment Full Waiver of
Premium, 2+ ADL Trigger, and 2% Participation |
|
APPENDIX Pc: PRESENTATION ENTITLED "ACTUARIAL
RESEARCH CORPORATION'S LONG TERM CARE INSURANCE MODEL"
Actuarial Research Corporations Long Term Care
Insurance Model
June 22, 2011
Caveats
- No one can foresee how this program will operate, therefore premiums
cannot be guaranteed to be adequate.
- Unknowns include level of participation, level of antiselection,
and the effectiveness of procedures to determine earnings, actively at
work, and qualifications for benefits, and the effect of providing
advocacy services
- Level premiums cannot be determined for benefits linked to an index
(CPI), because future benefits are unknown at the time that premiums are
calculated.
- Adequacy of premium cannot be guaranteed when premium levels are
unknown such as would be the case if premiums bounce up and down with
income.
Actuarial Basis For Premium Formula
- For each issue age, projections of benefits, expenses, and premium
income are made until age 100 (presumed to be the end of life for all
individuals in the cohort).
- The Premium for each issue age is set so that the present value of
benefits and expenses is equal to the present value of premium income.
Assumptions
- Premiums are calculated such that there is no subsidy across years of
issue or age at issue, as is typical of social insurance.
- Premiums are based on a set of assumptions:
- Interest Rates
- Mortality Rates
- Lapse Rates
- Expense Levels
- Utilization Rates
Source for Assumptions
- All assumptions may be modified b the user.
- Interest rates and mortality rates are taken from the 2011 OASDI
Trustees Reports.
- Lapse Rates are assumed to be 0.75% per year.
- Premium load for expenses is assumed to be 3%.
- Utilization comes from survey data with several adjustments.
Mortality Assumptions
- 2011 Trustees Report
- Mortality rates decline by roughly 0.8% per year
- Compared to 1994 GAM:
- Male GAM rates are about 99% of TR rates in 2011
- Male TR rates go below 1994 GAM in 2012
- Female GAM rates are about 83% of TR rates in 2011
- Female TR rates go below 1994 GAM in 2033
Utilization Assumptions: Data Sources for Nursing Home Rates
- For NH prevalence rates, incidence rates, average length of stay, and
continuance table: 1985 National Nursing Home Surveys (NNHS), trended to 2004
NNHS (generally about 20% to 40% reduction depending on age and sex).
Utilization Assumptions: Data Sources for Home Care Rates
- For HC ages 65+, incidence rates, average length of episode, and
continuance table: 1982-1989 National Long-Term Care Surveys (NLTCS) as
analyzed by Eric Stallard and Bob Yee, trended to 2004 by change in prevalence
rates from the 1989 to 2004 NLTCSs (generally about 20% to 50% increase
depending on age and sex).
- For HC ages <65, home care prevalence rates from the 2009 National
Health Interview Survey (NHIS). Average length of episode is extrapolated from
the over 65 (increased by 1% for each age, which is from about 3 1/2 years at
age 65 to about 5 3/4 years at age 18). Continuance table is from the over 65.
Incidence rates are derived from the formula:
- PR = IR * ALOS, which is equivalent to IR = PR / ALOS
Utilization Assumptions: Comparison of ARC Model Incidence
Rates to SOA Data for 2+ ADLs |
Age |
ARC Model (before
adjustments)* |
SOA 2004 Intercompany
Data |
Ratio |
45 |
.155% |
.13% |
1.2 |
55 |
.235% |
.14% |
1.7 |
67 |
2.20% |
.47% |
4.7 |
77 |
7.54% |
2.81% |
2.7 |
87 |
21.90% |
9.62% |
2.3 |
*
Excluded adjustments are for selection, antiselection, trend, and ADL creep.
Incidence rates are the sum of NH + HC incidence rates average of male and
female. |
Utilization Assumptions: Adjustments
- Utilization data are tabulated by age, gender, and ADL.
- Utilization of the under 65 are also tabulated by income level and
definition of cognitive impairment.
- We assume that 25% of those with one ADL less than the requirement
will receive benefits.
- We calculate the number of new beneficiaries in the first year of
benefit payments (2017) by using prevalence rates rather than incidence
rates.
Utilization Assumptions: Selection and Antiselection
- Selection: Provisions that result in participants being healthier
than average (average is based on survey data for the whole population).
- The 3-year work requirement
- NHIS data shows that ADL level of those that work ($1+ per year
$1) have significantly lower utilization than the total population
- Antiselection: Those in need of services are the most likely to
participate in an unsubsidized / voluntary program.
Utilization Assumptions: Selection
- Selection Factor: incidence rates in the last year of required work =
60% of ultimate
- Work is required for 3 out of the 5-year vesting period
- Selection wears off over 10-year period
Utilization Assumptions: Antiselection -- Two Methods
- Antiselectino Factor (AF) -- We model two different methods (and
other methods are possible):
- Formula based on a comparison of participation rates and
prevalence rates
- Estimate of additional 1st-year claims
- Additional First Year Claims
Formula Method of Antiselection
- A function of the participation rates and prevalence rates, assumed
to diminish over a 20-year period.
- Starts by first calculating a factor that represents the maximum
amount of antiselection and then dampens this factor.
- Maximum factor = 1/prevalence rate, if prevalence >
participation.
- Maximum factor = 1/(prevalence / participation), if participation
> prevalence.
- Different factor at each age and sex
Utilization Assumptions: Antiselection -- Examples
- Example 1 -- Male age 35 2+ ADLs: participation = 0.81% &
prevalence rates = 0.13%
- AF = 1/.0081 = 124 (perfect antiselection)
- AF = 100^0.7 = 29.2 (imperfect antiselction)
- AF(5) = 12.8 (interpolated value at duration 5)
- Example 2 -- Male age 55: participation = 3.43%, prevalence = 0.24%
- AF = 1/.034 = 29.2 (perfect antiselection)
- AF = 29.2^0.7 = 10.6 (imperfect antiselection)
- AF(5) = 6.0 (interpolated value at duration 5)
Additional First Year Claims Method of Antiselection
- Tabulate NHIS number of individuals that meet criteria for
participation and benefit eligibility.
- Assume that they all receive benefits in 2017 possible.
- * All = Dementia, developmental disabilities, mental retardation,
ADD, schizophrenia, bipolar.
- ** SRD = 1st 3 in list above
Income |
All* Cognitive or 2+ ADLs
(000) |
All* Cognitive or 3+ ADLs
(000) |
SRD** Cognitive or 2+ ADLs
(000) |
SRD** Cognitive or 3+ ADLs
(000) |
$0+ |
2,651 |
2,005 |
1,865 |
1,589 |
$1+ |
623 |
571 |
480 |
428 |
$10k+ |
412 |
374 |
315 |
277 |
Policy Options That Can Be Modeled
- Earnings requirement (parameter in law)
- Years of work required (3)
- Level for participation (quarter of coverage = $1,090 in
2009)
- Level for subsidy (poverty line = $10,830 in 2009)
- Benefit trigger (ADL requirement)
- Dollars per day of benefit including indexing options
- Indexing of premium
- Waiver of premium while in claim status
- While in nursing home
- And / or while in home care
- Deductible period
- Lifetime maximum
Assumptions That Can Be Modified
- Strength of antiselection
- Level of utilization
- Trend in utilization
- Lapse
- Interest
- Expense load
- Level of mortality
- Trend in mortality
Premium Sensitivity
- Final Set of assumptions for calculating premiums have not yet been
determined.
- Premiums are very sensitive to some assumptions.
- Low Income Subsidy / Income requirements
- Participation rates (1% to 4% decreases premiums by 13% to
18%)
- Indexing of premium (20+% reduction in initial premium)
- Interest (14% increase in premium for 4.7% interest vs 5.7%
interest with no change in CPI)
- Lapse (8% increase in premium for 0% lapse from 0.75%)
- Trends in mortality (4.3% decrease in premium by changing annual
trend from 0.75% to 0.25%) and morbidity
APPENDIX Pd: PRESENTATION ENTITLED "THE AVALERE
LONG-TERM CARE POLICY SIMULATOR MODEL"
The Avalere Long-Term Care Policy Simulator Model
June 22, 2011
Avalere Health LLC
Presentation Purpose and Agenda
- The purpose of this presentation is to describe Avaleres
approach for estimating the premiums for the CLASS Act, as written and with
modifications
- Agenda
- Provide brief project background
- Summarize overall modeling approach
- Highlight key issues/challenges
- Adverse selection
- Enrollment rates
- Questions/Discussion
Long-Term Policy Simulator (LTC-PS) Overview
Basic Overview
- The LTC-PS is an Excel-based spreadsheet model
- Originally built to allow policy makers to test a broad array of
public insurance policy options and subsequently modified for ASPE to allow for
testing CLASS-specific implementation policy options
- The LTC-PS is an incidence and continuance model
- Creates enrollment groups and calculates the age-specific costs
and premiums over a 75 year window
- Models incidence and continuance of disability to determine when
an individual becomes disabled and how long he or she remains disabled
LTC-PS Overview (cont.)
Data Sources
- Point-in-time surveys for prevalence of disability in the community
(Survey of Income and Program Participation, American Community Survey, Current
Population Survey) and in nursing homes (National Nursing Home Survey)
- Longitudinal survey for continuance rates among elderly aged 65+
(National Long Term Care Survey) and actuarial data for continuance rates among
disabled aged 18 to 65
- Data issues:
- No national, longitudinal data for disability across age
spectrum
- Aggregation of data from multiple surveys
- No single accepted method to estimate adverse selection
Model Overview |
|
Modeling Enrollment: Population and Program Eligibility
Overall Population
- We use Social Security estimates of the total population by age from
2010 through 2100 accounting for the agencys expectations for changes in
nativity, mortality, immigration, and emigration
Estimating Attachment to Workforce
- All workers: using data from the American Community Survey
(ACS), we calculate employment, unemployment, and the total labor force
(includes people who are working, unemployed individuals, and individuals
looking for work)
- Program eligible workforce: the CLASS program is open to all
individuals over 18 who have at least 3 years of working experience. We exclude
people who are disabled at the outset of the program unless they are currently
working (regardless of reported income)
- We estimate 5 to 7 percent of people with 2+ ADL disabilities in
the community setting are currently working (approximately 400,000 people)
Modeling Enrollment: Vesting
- We estimate compliance with the 5 year vesting period
- We consider two factors that result in an individual not meeting the
vesting requirements:
- Mortality: we use mortality estimates from the Social Security
Trustees report
- Policy Lapse: we assume a 0.5 percent lapse rate each year for
the first 20 years and after that we assume there are no additional policy
cancellations
Modeling Enrollment: Participation
Overall Participation
- Experts believe enrollment in CLASS will be between one and six
percent of eligible individuals
- We assume as a baseline that two percent of the working population
will enroll in the first year
- In subsequent years, we assume enrollment will be a fraction of the
baseline with declining enrollment rates for the next five years and finally
reaching a steady enrollment rate of 0.1 percent of the eligible population
- These estimates lead to non-low income enrollment of 2.2 million
in the first year; 145 thousand new enrollees in 2017; and total enrollment of
3.5 million in 2020.
- We then apply age-adjusted participation rates using two separate
methods: smooth enrollment and Federal Long-Term Care Insurance
Participation
Modeling Enrollment: Participation
Smooth Enrollment
- We set an enrollment inflection point at age 50 in the assumption
that the average participation would equal participation at age 50
- Increase participation at a rate of two percent for each age above 50
and decrease participation at a rate of one percent for each age below 50
- We use this method as our primary enrollment estimation
Federal Long-Term Care Insurance Participation
- We model a separate enrollment expectation rate based on the observed
enrollment rates in the federal long-term care insurance program (FLTCIP)
- We use the actual enrollment rates by age for in-force policies
Enrollment Estimation Methods |
|
Modeling Disability: Prevalence
Community Setting
- We estimate age-related prevalence from the 2004 Survey of Income and
Program Participation (SIPP)
- We define severe disability as needing help with two or more ADLs;
having Alzheimers Disease or another serious problem with forgetfulness
or confusion; having mental retardation or developmental disability (i.e.
autism, cerebral palsy)
- We estimate that 3 percent of the over-15 population in the community
has a severe disability
Nursing Home Setting
- We estimate age-related prevalence from the 2004 National Nursing
Home Survey (NNHS)
- We define severe disability as needing limited, extensive, or total
assistance with two or more ADLs; living in an Alzheimers or dementia
unit or having impaired decision making ability; was admitted to the nursing
home directly from an intermediate care facility for the mentally retarded
(ICF/MR)
- We estimate that 91 percent of the over-15 population residing in a
nursing home has a severe disability
Modeling Disability: Prevalence (cont.)
Prevalence OverTime
- Given the uncertainty about declining disability rates, we include a
decline of disability rates of 0.5 percent per year through 2025
- Overall disability prevalence is slightly above 3 percent from 2010
to 2025 and increases slightly after that to reach 4.6 percent by 2085
ADL creep
- In a CLASS program with a benefit trigger of 2 or more ADLs, we
assume that:
- 50 percent of individuals with just one ADL will qualify: all
nursing home residents and a portion of community residents
- In a CLASS program with a benefit trigger of 3 or more ADLs, we
assume that:
- 50 percent of individuals with 2 or more ADLs will qualify: all
nursing home residents with 2 ADLs and a portion of community residents
Modeling Disability: Continuance
- To estimate continuance, or how long someone remains severely
disabled, we use two data sets
- Over age 65: transition matrices from National Long Term Care
Survey1
- Under age 65: continuance tables from IDEC
survey2
- Non-continuance can be caused by two factors: mortality or
improvement in condition/recovery
- Tend to see improvement at younger ages: these individuals are
returned to the population eligible to pay premiums
- Mortality is higher for all ages of disabled individuals compared
to non-disabled individuals
- We required non-continuance to always be at least as high as
age-specific mortality from SSA
- Stallard, E and Yee, R.K.W. 1999. Non-insured Home- and
Community- Based Long-Term Care Incidence and Continuance Tables. Society
of Actuaries
- Society of Actuaries. 2005. Experience Studies in Individual
Disability.
Modeling Disability: Incidence
- Incidence can be computed once we have estimated prevalence and
continuance
- Prevalence P2 = Prevalence P1 + Incidence
I2 - Non Continuance NC2
- We apply incidence and continuance rates to individuals in each
program by age
Incidence Comparisons, 2+ ADLs |
|
Modeling Disability: Adverse Selection
- We increased incidence of participants in the LTC-PS to account for
adverse selection
- Enrolled population in voluntary program has higher disability
than general population
- Under the extreme scenario, every individual who would develop
disability within 5 years would enroll -- this is the perfect
knowledge scenario
- For the LTC-PS, we include a dampening factor to address the unlikely
nature of perfect knowledge:
- For the first enrollment group, we assume enrollment is weighted
at 75% to perfect knowledge scenario in the first year of benefit
eligibility
- We assume this ratio will decline over 20 years, reaching a final
weight of around 10%
- The starting weights are lower at a higher earnings requirement and
also dampened for estimates of future enrollment groups
Impact of Adverse Selection on Incidence, 2+
ADLs |
|
Adverse selection assumes
2 percent participation |
Modeling Costs: Medicaid Interactions
- We model the impact on Medicaid based on an assumption about
participation by people who would eventually become Medicaid enrollees and the
low-income subsidy
- We model a Medicaid baseline using data from SIPP and NNHS,
supplemented by information published by the Kaiser Commission on Medicaid and
the Uninsured
- Even with a low-income subsidy, some future Medicaid beneficiaries
would still be unlikely to enroll
- Not all future Medicaid beneficiaries are currently below the
Federal Poverty Limit (FPL)
- The table below shows our estimated participation rates by people who
would eventually become Medicaid beneficiaries by the different low-income
subsidy levels
- We apply these participation rates to our Medicaid baseline to
develop estimates of Medicaid savings
Premiums |
None |
100% FPL |
150% FPL |
<$50 |
25% |
50% |
75% |
$50-80 |
20% |
45% |
70% |
$81-100 |
15% |
40% |
65% |
$101-120 |
10% |
35% |
60% |
$121-150 |
5% |
30% |
55% |
>$150 |
0% |
25% |
50% |
Questions and Answers
APPENDIX Pe: PRESENTATION ENTITLED "ALTERNATIVE
APPROACHES TO CLASS BENEFIT DESIGN: THE CLASS PARTNERSHIP"
Alternative Approaches to CLASS Benefit Design:
The
CLASS Partnership
William Marton
Office of the Assistant Secretary
for Planning and Evaluation
June 22, 2011
CLASS Independence Benefit Plan |
|
CLASS Independence Benefit Plan October 1,
2012 |
|
CLASS Independence Benefit Plan |
|
Family of Options
- A set of benefit plans that are marketed as one plan with multiple
options
- One of the options must follow the CLASS statute fairly closely
(e.g., the Modified CLASS Plan)
- The structure of the other options can vary more extensively, but
still must maintain certain core features of the CLASS statute such as similar
requirements for enrollment; a primary benefit that is cash; a five year
vesting period; and no underwriting except for age
- The options are designed to appeal to different market segments of
the population that (hopefully) vary by the risk of adverse selection
- The family of options has to be actuarially sound, either at the
individual option level or in their entirety
CLASS Independence Benefit Plan |
|
CLASS Partnership
Basic: Incorporates the major features of the CLASS statute
(e.g., a primary benefit that is cash; no limit on duration; a vesting period;
and no underwriting except for age), but changes key components to mitigate,
although not likely eliminate, adverse selection.
Comprehensive: Provides much more comprehensive coverage (e.g., a
three-year $150 daily benefit) designed to appeal to people who want to insure
against future risk of long-term care that they will likely face at very old
ages. Structure of the benefit reduces the likelihood of adverse selection.
Short Term: Provides very short-term (e.g., one year), high
dollar coverage to persons with high functional needs. The premiums for this
product should be substantially lower than those for the Basic and
Comprehensive options, with the goal of appealing to persons who want some
level of coverage but cannot afford something more comprehensive. Similar
benefit structure as for the Comprehensive Option
Whyis this plan called the CLASS Partnership?
The structure of the benefit is designed to provide an opportunity for
private insurers to develop products that would naturally wrap
around and supplement the underlying core benefit. (Note: The supplement
would be underwritten.)
Specifically, the daily benefit amount increases the longer the policy
is held, rising from a nominal amount after the vesting period to an amount of
coverage similar to what is commonly purchased from long-term care
insurers.
However, unlike the CLASS Basic Plan, the duration of coverage for the
Comprehensive and Short Term options is limited.
Figure 1. Changes in Daily Benefit Amount for the
Comprehensive Option |
|
Summary of CLASS Partnership Plan |
Program
Features |
CLASS Benefit
in Statute |
CLASS Partnership
Plan |
Basic (Modified) |
Comprehensive |
Short Term |
Enrollment
Requirements: |
|
|
|
|
Age 18+ |
Yes |
Yes |
Yes |
Yes |
Taxable Wages/Income |
Yes |
Yes |
Yes |
Yes |
Actively Employed |
Yes |
Yes |
Yes |
Yes |
Not in Institution |
Yes |
Yes |
Yes |
Yes |
Coverage
Benefits: |
|
|
|
|
Primary Benefit |
Cash |
Cash |
Cash |
Cash |
Daily Benefit Amount (DBA) |
$50
(Average) |
$50
(Average) |
Varies - Up
to $1502 |
Varies - Up
to $2002 |
Unit of Payment |
Daily or
Weekly |
Daily or
Weekly |
TBD |
TBD |
Minimum Duration in Years |
NA -
Lifetime |
NA -
Lifetime |
3 Years |
1 Year |
Total Value |
TBD |
TBD |
$164,250 |
$73,000 |
Inflation Protection |
CPI-U |
CPI (2.8%) |
Variable4 |
Variable4 |
Advocacy Services |
Yes |
Yes |
TBD |
TBD |
Advice and Asst. Counseling |
Yes |
Yes |
TBD |
TBD |
Eligibility
for Benefits: |
|
|
|
|
5 Year Vesting Period |
Yes |
Yes |
Yes |
Yes |
Work Req. Over Vesting Period |
At Least 3
Years |
5 Years (or
40 Qs)5 |
5 Years (or
40 Qs)5 |
5 Years (or
40 Qs)5 |
Earnings Req. Over Vesting
Period |
$1,120/Year |
$12,000/Year |
$12,000/Year |
$12,000/Year |
24 Months of Prior Prem. Payment |
Yes |
Yes |
Yes |
Yes |
Minimum Benefit Trigger |
2 or 3 of 6
ADLs6 |
TBD |
HIPAA - 2+
ADLs6 |
HIPAA - 3+
ADLs6 |
Tiered Benefit |
Yes |
Yes |
No |
No |
Elimination Period in Days |
0 |
0 |
0 |
0 |
Presumptive Eligibility |
Yes - if in
Inst.7 |
Yes - if in
Inst.7 |
TBD |
TBD |
Administrative Expenses |
3% |
3% |
TBD |
TBD |
Monthly
Premium: |
|
|
|
|
Underwritten (Other Than Age) |
No |
No |
No |
No |
Indexed to Inflation |
No |
Yes (2.8%) |
Yes (3%) |
Yes (3%) |
Low Income Premium |
Yes |
Yes |
No |
No |
Full Time Student Premium |
Yes |
Yes |
No |
No |
Waiver of Premium |
TBD |
TBD |
TBD |
TBD |
Level Premium |
After Age
658 |
After Age
658 |
After Age
759 |
After Age
759 |
Return of Premium |
TBD |
TBD |
Yes10 |
Yes10 |
Indexed Monthly Premiums for CLASS Partnership:
Comprehensive Option (Scenario II - Expected) |
Age |
Core1 |
Supplement2 |
Total |
35 |
$109 |
$23 |
$132 |
40 |
$121 |
$32 |
$153 |
45 |
$138 |
$44 |
$182 |
50 |
$153 |
$73 |
$226 |
55 |
$162 |
$103 |
$265 |
60 |
$166 |
$144 |
$309 |
65 |
$168 |
$203 |
$371 |
Average |
$148 |
$99 |
|
- Full waiver of premium, 2%
participation
- 60% loss ratio, SOA experience data
|
Comparison of Comprehensive Level Premiums Against Private
LTC Insurance Plans |
Age |
Comprehensive (Total) |
MedAmer. Simplicity II1 |
Prudential LTC32 |
United of Omaha AS
Gold3 |
NW QCare4 |
FLTCIP5 |
35 |
$199 |
$238 |
$192 |
$182 |
$232 |
$74 |
40 |
$224 |
$270 |
$202 |
$193 |
$237 |
$87 |
45 |
$258 |
$308 |
$227 |
$201 |
$256 |
$104 |
50 |
$308 |
$356 |
$256 |
$214 |
$276 |
$125 |
55 |
$351 |
$415 |
$290 |
$234 |
$303 |
$153 |
60 |
$398 |
$498 |
$330 |
$280 |
$349 |
$187 |
65 |
$464 |
$621 |
$421 |
$402 |
$433 |
$238 |
- $4,500/month, $200,000 maximum (3.7 years), 30
day elimination period, 5% ACI, all cash
- $150/day, three year, 30 day elimination
period, 4% ACI, 40% HC in cash alternative
- $4,500/month, three year, 0 day elimination
period, 4% ACI, 40% HC in cash alternative
- $4,500/month, three year, 6 week elimination
period, 4% ACI, service reimbursement
- $150/day, three year, 90 day elimination
period, 4% ACI, service reimbursement
|
Indexed Monthly Premiums for CLASS Partnership: Short Term
Option (Scenario II - Expected) |
Age |
Core1 |
Supplement2 |
Total |
35 |
$72 |
$11 |
$83 |
40 |
$81 |
$15 |
$96 |
45 |
$92 |
$22 |
$114 |
50 |
$101 |
$37 |
$138 |
55 |
$106 |
$52 |
$158 |
60 |
$105 |
$75 |
$180 |
65 |
$101 |
$108 |
$208 |
Average |
$96 |
$51 |
|
- Full waiver of premium, 2%
participation
- 60% loss ratio, SOA experience data
|
For additional information, you may visit the DALTCP home page at
http://aspe.hhs.gov/_/office_specific/daltcp.cfm or contact the office at
HHS/ASPE/DALTCP, Room 424E, H.H. Humphrey Building, 200 Independence Avenue,
SW, Washington, DC 20201. The e-mail address is:
webmaster.DALTCP@hhs.gov.
Files Available for This Report
- Main Report
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/index.shtml
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/index.pdf
[48 PDF pages]
- APPENDIX A: Key Provisions of Title VIII of
the ACA, which Establishes the CLASS Program
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appA.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appA.pdf
[6 PDF pages]
- APPENDIX B: HHS Letters to Congress About
Intent to Create Independent CLASS Office
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appB.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appB.pdf
[11 PDF pages]
- APPENDIX C: Federal Register
Announcement Establishing CLASS Office
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appC.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appC.pdf
[2 PDF pages]
- APPENDIX D: CLASS Office Organizational
Chart
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appD.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appD.pdf
[2 PDF pages]
- APPENDIX E: CLASS Process Flow
Chart
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appE.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appE.pdf
[2 PDF pages]
- APPENDIX F: Federal Register
Announcement for CLASS Independence Advisory Council
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appF.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appF.pdf
[3 PDF pages]
- APPENDIX G: Personal Care Attendants
Workforce Advisory Panel
- Full Appendix
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appG.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appG.pdf
[6 PDF pages]
- Ga: Federal Register Announcement for Personal Care
Attendants Workforce Advisory Panel
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appGa.pdf
[3 PDF pages]
- Gb: Advisory Panel List of Members
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appGb.pdf
[2 PDF pages]
- APPENDIX H: Policy Papers Discussed by the
LTC Work Group
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appH.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appH.pdf
[36 PDF pages]
- APPENDIX I: CLASS Administration Systems
Analysis and RFI
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appI.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appI.pdf
[10 PDF pages]
- APPENDIX J: Additional Analyses for Early
Policy Analysis
- Full Appendix
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appJ.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appJ.pdf
[150 PDF pages]
- Ja: A Profile of Declined Long-Term Care Insurance
Applicants
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appJa.pdf
[23 PDF pages]
- Jb: CLASS Program Benefit Triggers and Cognitive
Impairment
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appJb.pdf
[65 PDF pages]
- Jc: Strategic Analysis of HHS Entry into the Long-Term Care
Insurance Market
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appJc.pdf
[33 PDF pages]
- Jd: Managing a Cash Benefit Design in Long-Term Care
Insurance
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appJd.pdf
[28 PDF pages]
- APPENDIX K: Early Meetings with
Stakeholders
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appK.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appK.pdf
[4 PDF pages]
- APPENDIX L: In-Depth Description of ARC
Model
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appL.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appL.pdf
[62 PDF pages]
- APPENDIX M: In-Depth Description of
AvalereHealth Model
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appM.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appM.pdf
[23 PDF pages]
- APPENDIX N: September 22, 2010 Technical
Experts Meeting
- Full Appendix
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appN.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appN.pdf
[37 PDF pages]
- Na: Agenda, List of Participants, and Speaker Bios
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appNa.pdf
[7 PDF pages]
- Nb: Presentation Entitled "Actuarial Research Corporation's Long
Term Care Insurance Model"
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appNb.pdf
[11 PDF pages]
- Nc: Presentation Entitled "The Long-Term Care Policy Simulator
Model"
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appNc.pdf
[11 PDF pages]
- Nd: Presentation Entitled "Comments on 'The Long-Term Care Policy
Simulator Model'"
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appNd.pdf
[7 PDF pages]
- APPENDIX O: Actuarial Report on the
Development of CLASS Benefit Plans
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appO.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appO.pdf
[47 PDF pages]
- APPENDIX P: June 22, 2011 Technical Experts
Meeting
- Full Appendix
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appP.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appP.pdf
[46 PDF pages]
- Pa: Agenda and Discussion Issues and Questions
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appPa.pdf
[8 PDF pages]
- Pb: Presentation Entitled "Core Assumptions and Model
Outputs"
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appPb.pdf
[7 PDF pages]
- Pc: Presentation Entitled "Actuarial Research Corporation's Long
Term Care Insurance Model"
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appPc.pdf
[11 PDF pages]
- Pd: Presentation Entitled "The Avalere Long-Term Care Policy
Simulator Model"
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appPd.pdf
[11 PDF pages]
- Pe: Presentation Entitled "Alternative Approaches to CLASS Benefit
Design: The CLASS Partnership"
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appPe.pdf
[8 PDF pages]
- APPENDIX Q: Table 2: Actuarial and
Demographic Assumptions
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appQ.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appQ.pdf
[2 PDF pages]
- APPENDIX R: Figure 1: Daily Benefit Amount
for Increased Benefit
- HTML http://aspe.hhs.gov/daltcp/reports/2011/class/appR.htm
- PDF http://aspe.hhs.gov/daltcp/reports/2011/class/appR.pdf
[2 PDF pages]
To obtain a printed copy of this report, send the full report title and
your mailing information to:
U.S. Department of Health and Human Services
Office of Disability,
Aging and Long-Term Care Policy
Room 424E, H.H. Humphrey Building
200
Independence Avenue, S.W.
Washington, D.C.
20201
FAX: 202-401-7733
Email: webmaster.DALTCP@hhs.gov
Where to?
Top of Page | Contents
Home Pages:
Disability, Aging
and Long-Term Care Policy (DALTCP)
Assistant Secretary for Planning and Evaluation
(ASPE)
U.S. Department of Health and Human
Services (HHS)
Last Updated: 11/16/2011