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Has HSA Enrollment Stalled?

While both the number of, and enrollment in, health savings accounts (HSAs) have grown significantly since HSAs first became available in 2004, data suggests that that growth may be slowing.

In 2017, enrollment estimates in HSA-eligible health plans vary considerably – from 21.4 million to 33.7 policyholders and their dependents, according to a new report. But, according to the nonpartisan Employee Benefit Research Institute (EBRI), there is one consistency between the enrollment estimates – most sources show that growth appears to have slowed in 2017, especially when looking at the market share of HSA-eligible health plan enrollment.

The report acknowledges that it can be challenging to determine how many people are enrolled in an HSA-eligible health plan and how that number has been changing. Indeed, the report notes that, for the most part, there are just a handful of surveys used to determine the number of people enrolled in an HSA-eligible health plan.

HSA ‘Accounts’

America’s Health Insurance Plans (AHIP), which, according to EBRI, generally reports the lowest estimate, has not released 2017 estimates yet. AHIP, EBRI/Greenwald & Associates and National Center for Health Statistics (NCHS) estimates are in the low-20-million range, while Kaiser Family Foundation (KFF) and Mercer estimates are in the low-30-million range. AHIP, EBRI/Greenwald & Associates, and NCHS cover the entire privately insured market, whereas KFF and Mercer cover only employment-based health plans. Hence, according to the report, the AHIP, EBRI/Greenwald & Associates, and NCHS estimates should be larger than KFF and Mercer – however, data shows just the opposite.

The EBRI report notes that these surveys are consistent in finding that there was very little growth in HSA-eligible health plan enrollment from 2014 to 2017. EBRI/Greenwald & Associates and KFF find that enrollment in HSA-eligible health plans was steady from 2016 to 2017, while Mercer and NCHS find that enrollment increased by 1 percentage point between 2016 and 2017. Three surveys – NCHS, KFF and Mercer – find a 2-4 percentage point increase in enrollment between 2015 and 2016. However, similar to the lack of growth between 2016 and 2017, four of the surveys find either no growth (Mercer and NCHS) or a one-percentage point growth (AHIP and KFF) between 2014 and 2015.

Signs of Growth?

Despite all the surveys showing little or no recent growth in HSA-eligible health plan enrollment, the EBRI/Greenwald & Associates survey at least finds data that implies enrollment growth. Specifically, a question related to the length of time someone had been enrolled in their health plan finds that 19% had been enrolled in their health plan less than one year, 28% had been enrolled 1-2 years, and 23% had been enrolled 3-4 years. And the EBRI report notes that if you look at the number of HSAs, rather than enrollment in HSA-eligible health plans, there are signs of growth.

EBRI explains that the surveys on enrollment count the number of people enrolled in an HSA-eligible health plan at a specific point in time, and that while the EBRI/Greenwald & Associates survey finds that 19% of enrollees are new (implying there is enrollment growth), no survey directly measures disenrollment from HSA-eligible health plans that may be offsetting new enrollment. Unpublished EBRI tabulations of enrollment and disenrollment data in the Truven Health Analytics’ MarketScan Commercial Claims and Encounters Database indicate that 10% of persons with individual coverage and 8% of persons with family coverage disenrolled from their HSA-eligible health plan between 2013 and 2014.

Account/Plan Disconnect?

Indeed, looking at data from the EBRI HSA Database, the report notes a potentially large number of HSAs that may no longer be currently associated with an HSA-eligible health plan. At the end of 2016, the EBRI HSA Database contained 2.0 million HSAs that did not receive any contributions in 2016, accounting for 36% of the accounts in the database. This lack of contributions may, according to EBRI, indicate that the accounts were no longer eligible for contributions because their account owner was no longer enrolled in an HSA-eligible health plan. In fact, EBRI notes that the percentage of accounts not receiving any contributions appears to be trending up, which they say would imply that simply looking at the number of accounts is not a good proxy to measure trends in HSA-eligible health plan enrollment.

While 2017 is a year with consistent low growth across the surveys, EBRI notes that there is at least one year in most of the surveys that shows low, no, and negative growth followed by a rather large jump in enrollment, and hence it is possible that such statistical anomalies are driving what appears to be low growth in 2017.

Ultimately, the report concludes that “more years and more research into this question are necessary to better understand trends in HSA-eligible health plan enrollment.”

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