2018 MIDTERM ELECTION

Time: D H M S

2018 Rate Hikes

The 2018 Rate Hike Project:

Back in 2015, I started tracking the individual market premium rate changes (mostly increases, occasionally a decrease) being requested by the various health insurance carriers on a state-by-state basis. At the time, I didn't bother separating out the initial requested rate hikes from the final, approved changes, so my final estimates ended up being a mixture of each. .Even so, I ended up being pretty damned accurate: I estimated that nationally, the overall average, unsubsidized, individual market policy rate increases would be roughly 12-13%, assuming 100% of current enrollees were to re-enroll in the exact same policy. I noted, however, that due to the likelihood of many people switching to different policies (either via the same carrier or a different one), the odds were that the effective average rate increases would turn out to be somewhat lower; likely "under 10% overall".

As it turned out, I called it pretty closely: The overall average approved rate hikes on the indy market (again, for unsubsidized enrollees) ended up being around 11.6-11.7% nationally...slightly below my estimates. Furthermore, the effective average rate hike once the dust settled turned out to be around 8% overall.

For 2016, I started the Rate Hike project earlier in the year, and made sure to add an extra column so I could compare the initial requested rate increases to the final, approved rate hikes...although it really didn't make much difference. While there were a lot of changes over the course of the summer/fall in 2015, in 2016, the approved rate changes ended up being pretty close to those requested in most instances. In the end, I estimated roughly a 25% overall national rate increase for unsubsidized enrollees. I also started tracking the small business market averages as well, although I only did this for a handful of states.

Once again, I nailed it pretty closely: The official ASPE report from the HHS Dept. gave the average as roughly 25%, but that only included the 38 states run via HealthCare.Gov; when you added the other 13 states, it dropped a bit to 22% nationally. However, that only included benchmark plans (the 2nd-lowest-priced Silver plans in each rating area). When you also roll in all the other policies available on the ACA-compliant indy market (Bronze, Gold, Platinum, Catastrophic and other Silver plans), it did indeed end up averaging closer to 25% after all.

This has become something of an annual off-season tradition for me; for good or for bad, I seem to spend 3 months of the year tracking exchange enrollments and the other 9 months of the year tracking how much unsubsidized rates for those same policies are going up. I'm once again tracking every state as comprehensively and accurately as I can as each one releases their initial, revised and final/approved rate changes. I'm also going to attempt to do this for the small business market in every state as well if I can, although those will be posted elsewhere if I'm sure I can lock them in for all (or nearly all) states.

Of course, thanks to the massive Trump/GOP Uncertainty Factor, there's a lot of unknowns at play for next year...and, as I've been predicting for months now, that uncertainty is already clearly leading to significantly higher rate hike requests than would otherwise be asked for. As of this writing I've only documented 4 states (Virginia, Maryland, Connecticut and Vermont), and already at least 4 insurance carriers (CareFirst, Evergreen Health, New Mexico Health Connections and BCBS of Tennessee) have gone on the record as pinning a significant chunk of their requested increases on uncertainty regarding Trump's threat to cut off CSR payments, whether or not HHS Sec. Price will bother enforcing the individual mandate penalty, whether or not the GOP at large will actually repeal the ACA and so on.

UPDATE 5/25/17: Several carrier CEOs have gone on the record to note that the Trump/GOP Uncertainty Factor is a "significant" or "primary" part of their requested rate hikes this year...but today BCBS of North Carolina went well beyond that, to explicitly say, point blank, that the CSR reimbursement issue is directly responsible for over 60% of their 22.9% requested increase. 

I've been assuming a ballpark average of 40% being due to general Trump/GOP/CSR uncertainty as a general rule of thumb. I'm sure it ranges widely from carrier to carrier, and I don't expect many other carriers to be quite so candid and specific about this issue, but BCBSNC has over half a million enrollees on the individual market (on + off exchange). That's 2.8% of the entire indy market all by themselves. Food for thought.

In any event, as always, it's important to remember several key caveats when reading the tables below:

  • These are for the individual health insurance market ONLY. Thes do not have anything to do with employer-sponsored policies (large or small), Medicare, Medicaid, the VA/TriCare, short term policies or "grandfathered/transitional" policies. These only refer to the roughly 18 million people enrolled in ACA-compiant individual market policies, either on or off the exchanges​.
  • The requested rate changes are oftentimes reduced (and, unfortunately, occasionally increased) by state insurance regulators. Sometimes they're approved exactly as is. Sometimes the carrier submits a revised request later in the summer/fall which is in turn approved or changed again. The green column at the end (APPROVED) likely won't be filled in for any states until sometime in October.
  • These are the full price, unsubsidized rate changes. For roughly 9 million exchange enrollees who are receiving APTC assistance, assuming their income level, etc. doesn't change much and they remain on the same policy, they likely won't see their rates go up much at all, since the tax credits will likely increase to match in most cases. The rate changes below apply mainly to the other 9 million people on the indy market who aren't receiving APTC assistance.
  • These average increases assume 100% of current enrollees renew their existing policy in 2018. This, obviously is not going to be the case for millions of people no matter what happens. Some carriers are dropping out of the market altogether. Some are dropping certain plans. Some are changing their policy offerings. Some are newly entering the individual market. In addition, the individual market has always had a lot of churn anyway, with people jumping in and out from year to year. Since there's no real way of accounting for all of that, I do the best I can with what I have at my disposal.

With all that in mind, here's where things stand as of 5/14/17: With 4 states plugged in (CT, MD, VT & VA) representing less than 6% of the total population, carriers are requesting a pretty unpleasant 32.5% average rate hike.

This will likely change dramatically as each new state is added to the spreadsheets. Once states representing over half of the population have been entered, it will take increasingly dramatic variances for each new state to move the needle up or down. Updates will be added at this link.

And with that, we're off...

UPDATE 5/16/17: OREGON ADDED. There are now 5 states representing around 7.1% of the total population included, with a weighted average requested rate hike of 29.84%.

UPDATE 5/19/17: DISTRICT OF COLUMBIA ADDED. There are now 6 states (DC is treated as a state here) representing 7.3% of the total population included, with a weighted average requested rate hike of 29.75%.

UPDATE 5/25/17: NORTH CAROLINA ADDED. There are now 7 states representing 11.2% of the total population included, with a weighted average requested rate hike of 27.5%. 

For 2017, North Carolina's unsubsidized, weighted average individual market rate hikes came in at around 24.2%. With carriers like Aetna, United Healthcare, Humana and Celtic all dropping out of the NC exchange market, there wasn't much math to do in order to find a weighted average: The only individual market carriers left were Blue Cross Blue Shield of NC, Cigna and "National Foundation Life Insurance", which is basically a non-entity shell company related to "Freedom Life", the less said about the better. Since Cigna only had around 1,200 indy market enrollees at the time (less than 0.5% of the total market share), that pretty much left BCBSNC as the only game in town, so their 24.3% hike was the whole shebang for the state.

The District of Columbia is the 6th state (OK, it's not a state but it's considered one legislatively for purposes of the ACA) to post their initial 2018 rate filings (h/t to Louise Norris for the heads up). For 2017, the weighted average rate increase for the individual market was a mere 7.3%, highly unusual for this year, while the small group market increase was almost non-existent: Just 0.4% overall.

While poking around in the SERFF rate filing database for different states, I occasionally find filings which DON'T apply to ACA-compliant policies or enrollees but which are of interest to healthcare nerds such as myself. I've decided to bundle these into a single post as they pop up, so check this entry once in awhile.

IOWA: Big Kahuna carrier Wellmark submitted a filing for non-ACA compliant small group policies (either grandfathered or transitional) which have effective/renewal dates of July, August or September 2017. The requested rate increase is 7.0% on average, which is pretty typical for small group plans, and it appears that Wellmark had 51,003 people enrolled in such policies as of 12/31/16. Nothing odd there.

What interested me, however, was this sentence:

Oregon is the 5th state to post their initial 2018 rate filings. Last year their weighted average increase was roughly 26.5% across 10 individual market carriers. This year I only see 8 carriers offering policies on the indy market, but the two missing are "Trillium" and "ZOOM", neither of which had more than a handful of enrollees to begin with.

As you can see, ATRIO Health Plans was refreshingly clear in their rate justification letter, not only listing the key numbers (covered lives, average increase) but the reasons for it: 4% due to the reinstatement of the ACA's carrier tax; 1% due to them choosing to shrink their own coverage area from 6 counties to just 2; an increase for smokers., etc. They list 4,250 people being impacted by the increase; I don't know the population of the other 4 counties they're pulling out of, but assuming they're roughly equal, around 8,000 current enrollees will have to shop around this fall.

Vermont is the 4th state to post their initial 2018 rate filings. Vermont has a couple of unusual policies re. their healthcare market: First, while they do technically have an off-exchange individual market, those policies are all fully ACA-compliant QHPs and are tracked exactly the same as on-exchange QHPs, meaning this dashboard report from February includes just about all of their individual market enrollees: 28,775 on exchange + 5,662 off-exchange, for a total of 34,437 ACA-compliant enrollees. Vermont didn't allow transitional plans, so aside from an unknown number still enrolled in grandfathered plans, that should represent their entire individual market.

UPDATE: As I've been warning for months, several carriers have now openly stated that perhaps 40% of their requested rate hike is due specifically to concerns about the Trump administration & the GOP's ongoing sowing of confusion and outright sabotage of the ACA and the individual market.

Connecticut is the 3rd state to post their initial 2018 rate filings.

Unlike most states, Connecticut did all the legwork for me, making it incredibly easy to plug the numbers into a spreadsheet for weighted average (requested, unsubsidized) rate hikes for both the individual and small group markets:

UPDATE: As I've been warning for months, at least one of Maryland's carriers has openly stated that perhaps 40% of their requested rate hike is due specifically to concerns about the Trump administration & the GOP's ongoing sowing of confusion and outright sabotage of the ACA and the individual market.

Maryland is the 2nd state to post their initial 2018 rate filings.

Last year they had 6 carriers participating in the individual market; this year it looks like all 6 are still planning to participate:

  • CareFirst Blue Choice, Inc​
  • CareFirst of Maryland Inc.
  • Group Hospitalization and Medical Services Inc. (GHMSI)
  • Cigna Health and Life Insurance Co.​​
  • Evergreen Health, Inc.​​
  • Kaiser Foundation Health Plan of the Mid-Atlantic States​​

The initial 2018 filings for four of the six carriers are pretty straightforward. Two of them are a bit tricky, though: Kaiser Permanente and Evergreen Health.

UPDATE: As I've been warning for months, at least one of VA's carriers has openly stated that perhaps 40% of their requested rate hike is due specifically to concerns about the Trump administration & the GOP's ongoing sowing of confusion and outright sabotage of the ACA and the individual market.

A couple of weeks ago I noted that Virginia is one of the first states to post their initial premium rate hike filings. At the time, they hadn't posted the actual filings but at least listed the insurance carriers which were planning on participating in the individual and small group markets next year, both on and off the ACA exchange: