Centers for Medicare and Medicaid Services Releases Reports on the Performance of the Exchanges and Individual Health Insurance Market

CMS NEWS FOR IMMEDIATE RELEASE July 2, 2018 Contact: CMS Media Relations (202) 690-6145 | CMS Media Inquiries                      Centers for Medicare and Medicaid Services Releases Reports on the Performance of the Exchanges and Individual Health Insurance Market Reports show individual market erosion and increasing taxpayer liability  Today, the Centers for Medicare and Medicaid Services (CMS) released three reports that provide important information on the current condition of the Federal and State-based Exchanges and state individual health insurance markets. Taken together, these reports show that state markets are increasingly failing to cover people who do not qualify for federal subsidies even as the Exchanges remain relatively stable. Steps taken by CMS in 2017, as the reports show, improved the performance of the Exchanges and began addressing market stability issues. However, serious problems persist. Rising premiums have left unsubsidized people with poor health coverage options and dramatically increased the federal cost of premium subsidies.  “As the Trump Administration took office, there were warning signs that we were dealing with a crisis in the individual health insurance market and Obamacare was failing its consumers. These reports show that the high price plans on the individual market are unaffordable and forcing unsubsidized middle class consumers to drop coverage,” said CMS Administrator Seema Verma. Additionally, these reports represent the current state of the market, as well as confirm our Agency’s efforts to stabilize the market. The three reports released today include the Early 2018 Effectuated Enrollment Snapshot, Exchange Trends Report, and new for this year, Trends in Subsidized and Unsubsidized Enrollment. The reports include data on effectuated Exchange enrollment for 2017 and 2018, overall trends on the operational and programmatic performance of the Exchange, and trends in subsidized and unsubsidized individual market enrollment from 2014 to 2017. These data provide a number of insights on how well state individual health insurance markets and Exchanges are serving the American consumer.  Serious problems in the individual health insurance market emerged in 2016. ·         The subsidized and unsubsidized enrollment report shows enrollment began to decline in some states between 2015 and 2016, and in particular among the unsubsidized portion of the market. Over that period, 23 states experienced a decline in unsubsidized enrollment, with 10 states experiencing double-digit declines.  ·         For plan year 2017, for which enrollment began in November 2016, the report shows an alarming 20 percent drop in the number of people nationwide who enrolled in the individual health insurance market without federal premium subsidies. By comparison, subsidized enrollment dropped by just 3 percent, or 223,000 people. ·         This enrollment drop occurred at the same time average monthly premiums spiked by 21 percent. ·         The unsubsidized portion of some state individual markets have clearly entered a death spiral, with unsubsidized enrollment dropping by more than a third in 14 states, including an astonishing 73 percent decline in Arizona. ·         These dramatic drops in enrollment occurred under the insurance rules and rates established under the previous Administration.  Immediate actions taken by CMS improved the performance of the Federal platform Exchanges and began addressing market stability issues. ·         CMS took immediate steps in 2017 to address market stability issues and to improve the performance of the Exchanges using the Federal platform in order to mitigate the deterioration of the individual health insurance market for consumers. The Exchange trends report shows a number of these initiatives are already improving the Federal platform Exchanges. ·         The Exchange Call Center reported an all-time high customer satisfaction rate of 90 percent. ·         CMS increased efforts to leverage the capabilities of the private sector by expanding the role of health insurance agents and brokers who supported 3,660,668 health plan enrollments, 42 percent of plan year 2018 open enrollments on Federal platform Exchanges. In contrast, Navigators enrolled less than 1 percent of total enrollees. ·         CMS also added new changes to Special Enrollment Periods (SEPs) to improve the risk pool by requiring people to verify their eligibility for an SEP.  As a result, the volume of exceptional circumstance SEPs granted by CMS declined by 56 percent for plan year 2017. ·         Consumer requests for SEPs continued to be served at a high level. Average response times for SEP verifications were one to three days and 90 percent of SEP applicants were able to satisfy SEP verification and begin coverage.  With enhancements to the Federal platform, enrollment through the Federal and State-based Exchanges remained steady into 2018. ·         Effectuated enrollment is when a person has selected or is automatically reenrolled in a plan and paid the first month’s premium, if applicable. The effectuated enrollment report shows that enrollment through the Exchanges remained steady for subsidized people moving into plan year 2018. In February 2018, 10.6 million individuals had effectuated their coverage through the Exchanges. This is approximately 3 percent higher than the 10.3 million people who had effectuated their coverage at the same time last year. ·         Those who enroll through the Exchanges increasingly rely on federal subsidies. The report shows 87 percent of enrollees rely on Advance Premium Tax Credits up from 84 percent for plan year 2017. ·         People who made a plan selection during open enrollment were more likely to have effectuated coverage in 2018. Nine percent of people failed to follow through with effectuating their coverage in 2018, compared to 15 percent in 2017.   Rising premiums dramatically increase the federal cost of subsidies and leave unsubsidized people with few if any coverage options. ·         The effectuated enrollment report also shows that average monthly premiums for coverage purchased through Exchanges rose another 27 percent in 2018 on top of the 21 percent increase consumers experienced in 2017. ·         This premium increase resulted in an even sharper increase in the average federal premium subsidy, which jumped by 39 percent in 2018, rising from $373 in 2017 to $520 in 2018.  ·         This increase in average premiums subsidy, as well as higher enrollment, will likely increase federal spending on premium subsidies by more than $17 billion in 2018. ·         Coverage options for the unsubsidized portion of the market were already bad in 2017 when 20 percent dropped coverage. Another 27 percent increase in premiums leaves unsubsidized people with few if any coverage options and likely resulted in another substantial decline in unsubsidized coverage for 2018.  It is clear that many Americans are being priced out of the health insurance market, especially for employed people who earn too much to qualify for tax credits and have no access to employer-sponsored coverage. This underscores the need for CMS to continue efforts to stabilize the market and provide all consumers—including those who do not qualify for large premium subsidies—with more affordable health coverage options.  CMS will continue to build on the significant steps already taken by the Administration to promote healthcare choice and competition and decrease costs. Americans should not be forced to choose between coverage they cannot afford and no coverage at all.   To see the reports, click the links below: Early 2018 Effectuated Enrollment Snapshot: https://www.cms.gov/CCIIO/Programs-and-Initiatives/Health-Insurance-Marketplaces/Downloads/2018-07-02-Trends-Report-1.pdf Trends in Subsidized and Unsubsidized Enrollment: https://www.cms.gov/CCIIO/Programs-and-Initiatives/Health-Insurance-Marketplaces/Downloads/2018-07-02-Trends-Report-2.pdf Exchange Trends Report: https://www.cms.gov/CCIIO/Programs-and-Initiatives/Health-Insurance-Marketplaces/Downloads/2018-07-02-Trends-Report-3.pdf ##### Get CMS news at cms.gov/newsroom, sign up for CMS news via email and follow CMS on Twitter CMS Administrator @SeemaCMS, @CMSgov, and @CMSgovPress.

CMS Takes Action to Modernize Medicare Home Health

CMS NEWS FOR IMMEDIATE RELEASE July 2, 2018 Contact: CMS Media Relations (202) 690-6145 | CMS Media Inquiries    CMS Takes Action to Modernize Medicare Home Health CMS Action for Home Health Agencies Puts Value Over Volume and Advances MyHealthEData Initiative WASHINGTON DC – Today, the Centers for Medicare & Medicaid Services (CMS) proposed significant changes to the Home Health Prospective Payment System to strengthen and modernize Medicare, drive value, and focus on individual patient needs rather than volume of care. Specifically, CMS is proposing changes to improve access to solutions via remote patient monitoring technology, and to update the payment model for home health care. “Today’s proposals would give doctors more time to spend with their patients, allow home health agencies to leverage innovation and drive better results for patients,” said CMS Administrator Seema Verma. “The redesign of the home health payment system encourages value over volume and removes incentives to provide unnecessary care.” CMS’s proposed changes promote innovation to modernize home health by allowing the cost of remote patient monitoring to be reported by home health agencies as allowable costs on the Medicare cost report form. This is expected to help foster the adoption of emerging technologies by home health agencies and result in more effective care planning, as data is shared among patients, their caregivers, and their providers. Supporting patients in sharing this data will advance the Administration’s MyHealthEData initiative. As required by the Bipartisan Budget Act of 2018, this proposed rule would also implement a new Patient-Driven Groupings Model (PDGM) for home health payments.  The current system pays for 60-day episodes of care and relies on the number of therapy visits a patient receives to determine payment. The PDGM would eliminate the use of “therapy thresholds” in determining payment and changes the unit of payment to 30-day periods of care. The improved structure would move Medicare towards a more value-based payment system that puts the unique care needs of the patient first while also reducing the administrative burden associated with the HH PPS. The PDGM would be implemented in a budget-neutral manner on January 1, 2020. The proposed rule also includes information on the implementation of home infusion therapy temporary transitional payments as required by the Bipartisan Budget Act of 2018. In addition, the proposed rule solicits comments on elements of the new home infusion therapy benefit category and proposes standards for home infusion therapy suppliers and accrediting organizations of these suppliers as required by the 21st Century Cures Act. Physicians who order home health services for their patients would also see administrative burden reduced under this rule.  CMS is proposing to eliminate the requirement that the certifying physician estimate how much longer skilled services would be needed when recertifying the need for continuing home health care, as this information is already gathered on a patient’s plan of care. The proposed rule helps advance the Trump Administration’s Meaningful Measures Initiative. CMS is proposing changes to the Home Health Quality Reporting Program (HH QRP). The cost impact related to updated data collection processes as a result of the proposed implementation of the PDGM and proposed changes to the HH QRP are estimated to result in a net $60 million in annualized cost savings to HHAs, or $5,150 in annualized cost savings per HHA, beginning in CY 2020. In the proposed rule CMS is releasing a Request for Information to welcome continued feedback on the Medicare program and interoperability. CMS is gathering stakeholder feedback on revising the CMS patient health and safety standards that are required for providers and suppliers participating in the Medicare and Medicaid programs to further advance electronic exchange of information that supports safe, effective transitions of care between hospitals and community providers. The proposed rule and the Request for Information can be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection. The proposed rule announced today is part of a broader effort to put patients over paperwork by improving access to and value of care, and reducing the administrative burden on physicians so that more effective care to patients may be provided.  To date, CMS has taken the following notable actions in this year’s rulemaking for Medicare, among others, to advance the Patients Over Paperwork initiative for Medicare beneficiaries: The modernizing proposals to advance CMS’ Meaningful Measures Initiative released in five separate fiscal year 2019 proposed rules are projected to save Medicare providers close to four million hours and more than $144 million as they take effect in 2019 and 2020. CMS proposed a Patient-Driven Payment Model for the Skilled Nursing Facility Prospective Payment System  that ties payment to patients’ conditions and care needs rather than volume of services provided and simplifies complicated paperwork requirements that save facilities approximately $2.0 billion over 10 years. CMS finalized a rule that would allow Medicare Advantage plans to offer more tailored plan benefit packages and new types of supplemental benefits. For a fact sheet on today’s proposed rule, please visit: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2018-Fact-sheets-items/2018-07-02.html For additional information about the Home Health Prospective Payment System, visit https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HomeHealthPPS/index.html and https://www.cms.gov/center/provider-Type/home-Health-Agency-HHA-Center.html. For additional information about the Home Health Value-Based Purchasing Model, visit https://innovation.cms.gov/initiatives/home-health-value-based-purchasing-model. For additional information about the Home Health Quality Reporting Program, visit https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Home-Health-Quality-Reporting-Requirements.html ### Get CMS news at cms.gov/newsroom, sign up for CMS news via email and follow CMS on Twitter CMS Administrator @SeemaCMS, @CMSgov, and @CMSgovPress.

Federal Legislation Related to Medicaid and Opioids: What to Watch

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Federal Legislation Related to Medicaid and Opioids: What to Watch With President Trump having declared the opioid epidemic a public health emergency, both the House and Senate are advancing legislation to address the crisis. A new issue brief from the Kaiser Family Foundation summarizes current federal legislative proposals related to Medicaid’s role in the opioid epidemic and identifies issues to watch as final legislation takes shape. The House has passed several bills culminating in the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act. The Senate Finance Committee has approved the Helping to End Addiction and Lessen (HEAL) Substance Use Disorders Act, which is expected to be considered by the full Senate later this year. Appendix tables detail the House SUPPORT Act, the Senate HEAL Act, and other bills pending at the Senate and House committee level as of late June, 2018 Any final legislation could affect state Medicaid programs, SUD treatment providers, health plans, beneficiaries and other stakeholders. To see more of KFF’s work related to the opioid epidemic visit our special resource page on this topic. Filling the need for trusted information on national health issues, the Kaiser Family Foundation is a nonprofit organization based in San Francisco, California.
Contact: Chris Lee | (202) 347-5270 | clee@kff.org
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Social Security’s Purchasing Power Down 34% Since 2000

Pantagraph (Bloomington, IL) July 1, 2018

July 01--Each month, more than 62 million people receive a Social Security check. Of these eligible beneficiaries, nearly 45 million are aged beneficiaries, 62% of which rely on Social Security to provide at least half of their monthly income. Suffice it to say that without the guaranteed payout that Social Security offers, the elderly poverty rate in this country would otherwise be significantly higher than it is now.

Yet, truth be told, the average retired worker benefit isn't all that high. According to data from the Social Security Administration, the average retired worker received $1,412.14 in May 2018, or $16,946 a year. That's less than $5,000 above the federal poverty line for a single individual.

Even more interesting, or should I say worrisome, is the fact that, according to a new analysis from The Senior Citizens League (TSCL), a nonpartisan group that represents the interests of senior citizens, the purchasing power of these Social Security dollars has been falling precipitously since the turn of the century.

In the "2018 Social Security Loss of Buying Power Study," where more than 1,000 seniors from across the country were surveyed about their annual cost-of-living adjustment (COLA) and a bevy of expenses they've paid, it was determined that Social Security benefits have lost 34% of their purchasing power since the year 2000. In plainer terms, what $100 in Social Security income would have bought in goods and services in 2000 now buys $66 worth of goods and services.

Should these findings really shock anyone? Probably not. A May 2018 TSCL survey found that despite receiving a 2% "raise" (i.e., COLA) from Social Security in 2018, a combined 50% of respondents either saw their benefit drop, stay the same as in 2017, or rise by $5 or less, thanks to the hold harmless provision. Meanwhile, 56% of the "Loss of Buying Power Study" respondents said their expenses rose by more than $79 in 2018.

As an aggregate, TSCL notes that the average Social Security benefit has increased by 46% since 2000. However, the 39 costs it examined, which are representative of expenses that seniors often deal with, rose by an average of 96.3% over this same time period. Assuming an average benefit of $816 per month back in 2000, the typical retiree today needs $410 more a month from Social Security than they're currently receiving just to be on par with where they were 18 years prior.

In particular, TSCL listed 10 expenses that have more than doubled since 2000, including Medicare Part B premiums (up 195%), annual average out-of-pocket prescription drug expenses (up 188%), homeowner's insurance (up 164%), Medigap plans (up 158%), and property taxes (up 129%), to name a few.

Social Security has an inflation problem that's incredibly difficult to fix

Ultimately, aged beneficiaries are getting the short-end of the stick because America's most important social program has an inflation problem.

As it stands now, Social Security's COLA is tethered to the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). As the name suggests, it measures the expenditures of urban and clerical wage earners, many of which are considerably younger than retired workers. As a result, medical expenses and housing costs aren't being properly reflected in the inflation calculations each year, while other expenses, such as apparel, education, and transportation, are being overemphasized.

Image source: Getty Images.

While there is a fix, it isn't without its own set of consequences. The Consumer Price Index for the Elderly, or CPI-E, would specifically take into account the expenditures of households with seniors aged 62 and over. If the CPI-E were used in place of the CPI-W, it would more accurately reflect the costs that seniors face, therefore providing them with a healthier annual COLA, and possibly reducing their persistent loss of purchasing power. This is a solution regularly offered by Democrats on Capitol Hill.

But here are the catches. First, the CPI-E fails to take into account Medicare Part A expenses and Part B premiums, which aren't taken into account by the traditional CPI-W, either. As a result, even with more emphasis being placed on medical expenses, the CPI-E would still, likely, underreport the actual medical expense inflation seniors are facing.

The other issue is that boosting Social Security's COLA could more quickly put the program in dire straits. As a reminder, the Board of Trustees' annual report, released in June, projects that the program will begin paying out more in benefits than it generates in revenue this year. By 2034, the $2.9 trillion in asset reserves that have been accumulated over decades will be completely exhausted, potentially leading to an across-the-board cut in benefits of up to 21%. By increasing COLA via the switch to the CPI-E, this 2034 exhaustion date could be moved forward.

Comparatively, Republicans have proposed swinging the pendulum in the other direction by using the Chained CPI in place of the CPI-W. The Chained CPI and CPI-W are similar in how they measure inflation, with one notable difference: substitution bias. The Chained CPI takes into account the desire of consumers to trade down to cheaper goods and services when one gets too pricey. Because of this trade-down assumption, the Chained CPI tends to grow more slowly than the CPI-W, and much slower than the CPI-E. In essence, it would probably result in even larger purchasing power losses for seniors.

At the end of the day, Democrats and Republicans are so fiercely divided over Social Security that nothing is getting done. If the GOP were to be successful in pushing for the Chained CPI, seniors would lose additional purchasing power. If Democrats went with the CPI-E, seniors might find some temporary relief, but would likely still lose purchasing power and bring Social Security's longer-term dilemma to head even faster. This inflation problem isn't an easy fix, and it's liable to continue ravaging the pocketbooks of seniors for some time to come.

The $16,728 Social Security bonus most retirees completely overlook

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(c)2018 The Pantagraph (Bloomington, Ill.)

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Explaining Stewart v. Azar

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Explaining Stewart v. Azar, the Federal District Court Decision Invalidating Kentucky’s Medicaid Waiver A new issue brief from the Kaiser Family Foundation explains the June 29 federal court ruling invalidating the Kentucky HEALTH Medicaid waiver program and its implications for other states. The DC Federal District Court decision in Stewart v. Azar blocked Kentucky from implementing the waiver on July 1, including its work requirement, monthly premiums up to 4% of income, coverage lockouts for failure to timely renew eligibility or timely report a change in circumstances, and other provisions. The court held that the primary purpose of Medicaid is to provide affordable health coverage. It determined that the approval of the waiver by the federal secretary of Health and Human Services violated the law because he did not consider the plan’s impact on furnishing medical assistance – providing affordable health coverage -- to the low-income populations identified by Congress in the Medicaid statute. Specifically, the secretary never discussed how many people would lose coverage, despite the state’s estimate that 95,000 people would lose Medicaid, the court found. The secretary also failed to cite any evidence that some enrollees would gain private coverage as a result of the waiver or estimate how many might do so. In addition, the court found that the secretary cannot prioritize the impact on “traditional” or “vulnerable” Medicaid populations at the expense of the Medicaid expansion group. The court vacated the waiver and remanded it to HHS to make a decision that is supported by the administrative record. The ruling comes at a time when the Trump Administration is encouraging states to impose work requirements in Medicaid. The decision sets the stage for appeals and future litigation that could affect the other states with approved work requirement waivers as well as how HHS and the states address these issues in the future. For more information on which states are seeking waivers for work requirements and other provisions, visit our Medicaid waiver tracker. Filling the need for trusted information on national health issues, the Kaiser Family Foundation is a nonprofit organization based in San Francisco, California.
Contact: Chris Lee| (202) 347-5270 | clee@kff.org
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SHORT-TERM INSURANCE SCORING ROUNDUP

Jonathan Keisling June 29, 2018

In February, the Trump Administration released its proposed rule on short-term limited-duration insurance (STLDI) plans for health care. The rule would change the legal duration of STLDI plans from three months to 364 days, allowing them to function like traditional insurance. This rule, partnered with the individual mandate penalty of $0 beginning in 2019, will likely produce observable effects for the non-group insurance marketplace. STLDI plans do not need to comply with the Affordable Care Act’s insurance market reforms and therefore feature a narrower range of benefits partnered with premiums that are significantly lower on average.

Multiple scorekeepers have weighed in on what effects the proposed rule might have.

Each of the analyses in the table above had its own set of assumptions and objectives. The Congressional Budget Office noted its results within its most recent baseline update. The Urban Institute and the Commonwealth Fund sought to analyze the STLDI rule, but they both also included in their analyses the combined effects of the new individual mandate penalty and the STLDI rule. Meanwhile, the Center for Health and Economy already included the new mandate penalty in their baseline and only considered the effects of the STLDI rule.

Correctly predicting the future is hard in general, and scoring STLDI plans presents its own peculiar challenges. The scorekeepers point out that this rule will affect every level of the insurance marketplace. Factors that could change include: insurers’ decisions to offer qualified health plans, insurers’ rate setting, risk-pool make up, consumer behavior, and STLDI plan designs themselves. Each score deals with these uncertainties differently, either by providing a range of outcomes or by outlining their assumptions.

What can be learned from the analyses? Despite the differences in the aims of each score and the magnitudes of its predictions, there seems to be a consensus that, by virtue of their low premiums, STLDI plans will be attractive to consumers, and thus enrollment will likely be in the millions. Each scorekeeper concludes that both those currently insured and the uninsured will purchase STLDI plans, and that premiums will rise in other non-group plans because some of those currently insured will shift into STLDI plans. Yet even though premiums for the rest of the non-group marketplace will rise, each scorekeeper expects non-group enrollment to increase overall.

Whether or not these outcomes ultimately prove good for consumers and the market, the administration’s new regulation on STLDI plans will be consequential.

https://www.americanactionforum.org/weekly-checkup/short-term-insurance-scoring-roundup/#ixzz5K6oB04M2
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Valuing Your Equity Stake in the Federal Government

The old joke is that the federal government has become a large financial institution with side businesses in national defense and poverty programs — think of the myriad financial products it offers: health insurance, flood insurance, mortgage insurance, student loans, small business loans, crop insurance, and more. Viewed from that perspective, the taxpayers are the equity investors in this large financial institution. How should they think about the risks of this investment?  The Congressional Budget Office (CBO) put out a nice reminder this past week entitled “Fair-Value Estimates of the Cost of Federal Credit Programs in 2019” that contained the following summary:

Using FCRA [Federal Credit Reform Act] procedures, CBO estimates that new loans and loan guarantees issued in 2019 would result in savings of $37.4 billion. But using fair-value procedures, CBO estimates that those loans and guarantees would have a lifetime cost of $37.9 billion. More than 80 percent of the difference between those amounts comes from three sources:

• The guarantees that Fannie Mae and Freddie Mac will make in 2019, analyzed on a FCRA basis, are projected to save the federal government about $23.5 billion. under fair-value accounting, however, the guarantees would cost about $2.5 billion.
• The Department of Education’s student loan programs are projected to save $4.1 billion on a FCRA basis but to cost $16.1 billion on a fair-value basis.
• The Department of Housing and Urban Development’s (HUD’s) loan and loan guarantee programs are projected to save $9.5 billion on a FCRA basis but to cost $7.1 billion on a fair-value basis.

In short, looked at in one way (FCRA) the financial institution’s 2019 book of business made $37.4 billion, while looked at another (fair-value) it lost $37.9 billion. What is going on?

When the CBO (or the Office of Management and Budget, OMB) looks at a loan, insurance product, loan guarantee or other financial transaction it follows a simple procedure: (a) it looks over the entire lifetime of the transaction, (b) it calculates the year-by-year outflows from the Treasury, (c) it calculates the year-by-year inflows of payments to the Treasury, and (d) it calculates the net cash amount in the present that has the same lifetime value as owning (b) and (c). (This is known as the “present” value of the those cash flows.) CBO is saying that the FCRA approach indicates that owning the cash flows is the same as having $37.4 billion in your pocket — a good thing — and the fair-value approach indicates that it is the same as owing $37.9 billion — a bad thing.

The essential thing to notice is that the two approaches use exactly the same year-by-year cash flows in and out of the Treasury. There is no disagreement about the performance of the financial product. They differ only in how they treat the risk in the environment surrounding the transaction. The FCRA approach ignores those risks — recessions, recoveries, market booms, market busts, etc. It treats a dollar taken from the private sector in good times the same as a dollar taken in bad times, and a dollar paid out in good times the same as a dollar in bad times. But in bad times, cash is dear and payments made are more costly and cash received more valuable than when the economy is flush. The fair-value approach incorporates this market risk into its valuation of the programs.

Looked at from this perspective, the federal government is involved in activities — especially in housing and education — that might look good on average (FCRA), but when they go bad, they go really bad at the worst time (fair-value). The failure to anticipate and prepare for this risk is exactly why Fannie Mae and Freddie Mac are in conservatorship and the remaining loan programs are on dicey financial footing. It is important information for taxpayers because they may be uncomfortable with holding those risks, which would mean that it makes sense to reform the loan and guarantee programs.