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.

UPDATE 6/02/17: OK, between North Carolina (60% due specifically to sabotage) and Pennsylvania (75% due specifically to sabotage), I'm bumping my ballpark average assumption up to a flat 50% due to the "Trump Uncertainty Tax" in states which don't otherwise specify the impact. I've also added new columns to the tables below which compare the total rate hike requests vs. what they likely would be without the Trump Tax included.

UPDATE 6/7/17: New York has released their rate requests with the opposite situation: They were instructed to assume CSR payments/etc will continue,  which means they're only providing the "NO Trump Tax" scenario. In these cases I'm going to rely on the Kaiser Family Foundation, which estimated that rates would have to be increased an average of 9-27% depending on the state, averaging around 19% overall, 21% for non-Medicaid expansion states and 15% for Medicaid expansion states.

FURTHER UPDATE: Just realized that due to the BHP programs in NY/MN, those states only have 1/3 as many CSR enrollees anyway, so the Trump Tax is likely more like 5 points instead of 15 points in each. Tables revised below.

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%. 

UPDATE 6/2/17: PENNSYLVANIA ADDED. There are now 8 states representing 14.8% of the total population included, with a weighted average requested rate hike of 29.7% with the Trump Tax or 11.0% without it.

UPDATE 6/7/17: NEW YORK ADDED. There are now 9 states representing 18.3% of the total population included, with a weighted average requested rate hike of 30.4% with the Trump Tax or 11.9% without it.

UPDATE 6/9/17: MAINE ADDED and CONNECTICUT CORRECTED. There are now 10 STATES representing 18.8% of the total population included, with a weighted average requested rate hike of 13.1% WITHOUT the Trump Tax or 34.2% WITH it.

UPDATE 6/14/17: DELAWARE and MICHIGAN ADDED. There are now 12 STATES representing 21.8% of the total population included, with a weighted average requested rate hike of 13.7% WITHOUT the Trump CSR Tax or 33.1% WITH it.

UPDATE 6/19/17: WASHINGTON STATE ADDED. There are now 13 STATES representing 23.8% of the total population included, with a weighted average requested rate hike of 13.3% WITHOUT the Trump/GOP Sabotage Tax or 32.2% WITH it.

UPDATE 6/20/17: IOWA ADDED. There are now 14 STATES representing 24.6% of the population included, with a weighted average requested rate hike of up to 13.6% WITHOUT the Trump/GOP Sabotage or 32.6% WITH the Trump/GOP Sabotage Tax included.

ALSO NOTE: Going forward, I'm changing the "WITHOUT TrumpTax" label to "w/NO or PARTIAL TrumpTax" because some carriers don't break out their "HHS mandate enforcement uncertainty" factor even if they break out the "assume no CSR reimbursements" factor. This means that the "Without" average is actually somewhat lower than shown overall, but I have no way of estimating how much lower, though my guess is it'd be perhaps 2 points or so overall.

Louise Norris gave me a heads' up regarding the Indiana 2018 rate filings. Anthem BCBS and MDwise, which currently have around 46,000 and 30,800 exchange enrollees each, are dropping out next year, meaning nearly 77,000 people will have to shop around. Anthem is sticking around the off-exchange market....but only in a handful of counties. Norris indicates around 64,687 total Anthem enrollees; minus the 46K on-exchange, that leaves roughly 18.7K off-exchange enrollees, virtually all of whom are expected to drop due to Anthem dropping out of all but 5 counties (plus, of course, the large rate hike).

Things are looking pretty precarious in Iowa for 2018, with Wellmark and Aetna bailing entirely on the state's individual market.

The good news, such as it is, is that Medica has stepped up to the plate as the sole insurance carrier filing to offer indy market policies (on the ACA exchange or off, I believe) across all 99 counties next year.

The bad news--although I can't really say that I blame them under the circumstances--is that they're insisting that they'll need a big rate hike to do so.

Here's the thing, though: First check out the headline in this story about it from The Hill:

Only ObamaCare insurer in most Iowa counties to hike premiums by 43.5 percent

One of the last insurers on Iowa's ObamaCare exchanges announced Monday it would sell plans in 2018 but proposed an average rate increase of 43.5 percent.

h/t to Rebecca Stob for the heads up:

OLYMPIA, Wash. - Eleven health insurers filed 71 health plans for Washington state’s 2018 individual and family health insurance market, with an average proposed rate increase of 22.3 percent. No health insurer filed plans in two counties – Klickitat and Grays Harbor.

Insurance Commissioner Mike Kreidler has been reaching out to insurers since they filed their plans on June 7 to see if one or more will reconsider offering plans in the bare counties.

“I’m very concerned by the proposed changes we’re seeing,” Kreidler said. “I know these numbers will be extremely upsetting to people who buy their own health insurance. They’re upsetting to me. We’re going to spend the next several months reviewing every assumption insurers have made to make sure their proposed increases are justified.

For heaven's sake. Here I sit, painstakingly digging up, downloading, compiling and analysing a mountain of 2018 SERFF rate filing forms for hours on end to find out what the weighted average requested rate hikes are in every state and to then go beyond that to figure out how much of the increases are due to normal factors vs. Trump/Price/GOP-specific sabotage efforts such as the threat to cut off CSR payments and/or not to enforce the individual mandate penalty...

...and then a big healthcare consulting firm like Oliver Wyman goes and steals my thunder by issuing hteir own analysis:

Two market influences, in particular, are complicating 2018 rate setting: the uncertainty surrounding continued funding of cost sharing reduction (CSR) payments and the question of how the relaxation of the individual mandate will impact enrollment and risk pools.

Calculating the average requested rate hike in Delaware is easier than most states. This year they officially have 5 carriers participating in the individual market (3 on exchange, 2 off)...but one of those is "Freedom Life" which is a phantom carrier; another is Golden Rule which only has about 120 enrollees; and two of the others are divisions of Aetna, which is dropping out of Delaware's indy market next year altogether. That leaves just Highmark BCBS, unless Golden Rule has surprised me by enrolling a significant number of people off-exchange this year.

Today the Delaware Dept. of Insurance issued this press release:

Highmark Requests 2018 Health Insurance Rate Increase of 33.6%

Date Posted: Wednesday, June 14th, 2017

Normally I don't post my Rate Hike Project analysis for a state until I have rate filing data available for all (or nearly all) of the individual market enrollees on hand.

I'm making an exception in the case of Michigan, however, because a) it's my home state, and b) My wife, son and I happen to be enrolled in an ACA exchange policy ourselves, via Blue Care Network (the HMO division of Blue Cross Blue Shield of Michigan).

Unfortunately, as of today (6/13) only one carrier has submitted their 2018 rate filing for the ACA-compliant individual market...and it's BCBSMI itself. That is, the PPO division of Blue Cross, not the HMO division.

(sigh) OK, this is getting very confusing now.

The good news for me out of Maine is that they've released the filings for all three individual market carriers for 2018 (Aetna has around 1,000 enrollees but they're leaving the individual market entirely), and all three include the exact number of current enrollees, making the average rate hike request simple enough on the surface: 21.2% for Anthem, 39.7% for Harvard Pilgrim (HPHC) and 19.6% for Maine Community Health Options (one of the few remaining ACA-created CO-OPs*), for a weighted average unsubsidized increase request of 25.2%.

*UPDATE: My mistake! I accidentally confused MCHO with Evergreen Heatlh of Maryland, which is in the process of converting itself from a Co-Op into a private carrier! Thanks to Louise Norris for the catch!

This just in from the Washington State insurance commissioner's office...

Eleven health insurers file for 2018 individual market in 37 counties, leaving two with no coverage
Kreidler: Trump administration’s actions fuel insurers’ uncertainty, harm consumers

Eleven health insurers have filed 71 plans for Washington state’s 2018 individual health insurance market:

  • Six insurers inside the Exchange, Washington Healthplanfinder.
  • Eight insurers outside the Exchange.
  • Two insurers selling both inside and outside the Exchange.
  • Currently, no insurer has filed plans in two counties – Klickitat and Grays Harbor.

Two insurers, Community Health Plan of Washington and Kaiser Foundation Health Plan of Washington Options, announced earlier this year that they will not participate in the 2018 individual health insurance market.

Thanks to Bill Hammond of the Empire Center for the heads up.

Like Pennsylvania, the New York Dept. of Financial Services made it very easy for me this year:

This chart sets forth the average premium rate adjustments that health insurers have requested from the New York State Department of Financial Services (DFS). There are 16 insurers that have submitted individual rates and 20 insurers that have submitted small group rates for 2018. These are the rates insurers have requested and are not the final premium rates DFS will approve. Under the Insurance Law, the Superintendent may deny or modify the requested rates if she finds that the insurer's request is unreasonable, excessive, discriminatory or inadequate based on sound actuarial assumptions and methods (Insurance Law §§ 3231(e)(1), 4308(c)). From the date DFS posts insurer rate applications on the DFS website, the public will have 30 days to submit comments to DFS on the proposed rates. The total percentage requested rate increase for individual and for small group on the chart below represent a weighted average that accounts for the relative share of overall enrollment for each insurer.

I've been warning for months now that the Trump administration is doing everything possible to disrupt, undermine and otherwise sabotage the ACA exchanges as much as possible. Yes, the GOP in general has been doing so for 7 years now, but they've really shifted it into overdrive now that they hold all the cards.

In the past, some of those sabotage efforts were obvious and had a direct impact on the exchanges (the Risk Corridor Massacre, for instance) while others were smaller, less obvious and harder to pinpoint a precise cause/effect relationship (red states attempting to obstruct ACA navigators, for example). Donald Trump and his rogue's gallery of cretins are not exactly known for their subtlety, however, so his obstruction/sabotage efforts have been pretty blatant, including:

Pennsylvania is way too easy for me this year; I don't even have to plug numbers into a spreadsheet to figure out the statewide average rate hikes.

Why? Because the state insurance commissioner has already done the math for me...and then some:

Insurance Commissioner Announces Single-Digit Aggregate 2018 Individual and Small Group Market Rate Requests, Confirming Move Toward Stability Unless Congress or the Trump Administration Act to Disrupt Individual Market

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.

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