Indiana: *Final* avg. 2020 #ACA premium rate hikes: IN DOI says 9.7%. The math says 13.5%.

Back in early July, the Indiana Insurance Dept. posted the preliminary requested 2020 rate increases for the carriers participating in the ACA-compliant individual market. Technically there's three carriers there (CareSource Indiana, Celtic/Ambetter and Anthem), though Anthem only has 4 (yes, four) people enrolled in off-exchange policies total.

At the time, the IN DOI stated that the requested rates came in at an average premium increase of 9%:

INDIANA 2020 ACA FILINGS

The overall average rate increase for 2020 Indiana individual marketplace plans is 9.0%. CareSource and Celtic (MHS/Ambetter) have filed to participate in the 2020 Indiana Individual Marketplace. The Department of Insurance anticipates that all 92 counties in Indiana will be covered by both CareSource and Celtic (MHS/Ambetter).

Anthem has filed to offer a 2020 Off-Marketplace plan in Indiana. This plan is a catastrophic plan and is offered only in Benton, Jasper, Newton, Warren and White Counties.

Filing a rate does not guarantee it will be approved for use on the Marketplace, nor does the filed rate guarantee to be the final rate. Therefore, the Department of Insurance is not able to ascertain the amount of any final rates at this time. The state has until September 24, 2019 to review and submit dispositions to U.S. Department of Health and Human Services.

However, when I plugged the hard numbers into a spreadsheet, I came up with a weighted average increase of 10.2%:

At the time I didn't think much of it; I figured there was some clerical bugaboo accounting for the discrepancy.

Today, however, I revisited the actual SERFF filings for all three carriers, and discovered that since July, two of the three have resubmitted their 2020 filings with increases which go beyond their preliminary requests:

CareSource has bumped up their rate hikes from 3.5% to 4.9%, while Celtic/Ambetter has increased theirs from 14.3% to 18.9%. This is highly unusual--in almost all other cases, the revised rate changes are lower than the initial ones.

In any event, these changes raise the actual weighted average from 10.2% to 13.5%:

The IN DOI hasn't issued any further updates, and it's entirely possible that the final, approved rates for 2020 will end up at 9% as they stated in July...but in the meantime, there's a 4 1/2 point gap between their stated numbers and mine.

UPDATE 10/11: Welp. According to this, the Indiana Dept. of Insurance has indeed approved the rate increases listed above exactly as I have them: 4.9%, 18.9% and 3.0% respectively...and the final versions of the rate filings have clear, specific effectuated enrollment numbers for all three carriers (two on & off-exchange, one off-exchange only). Yet IN DOI insists that the weighted average is only 9.7%.

The math is clear and complete. I don't see any possible way that Indiana's avg. 2020 increase could be just 9.7% instead of 13.5%.