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/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.

UPDATE 7/2/17: INDIANA and TENNESSEE ADDED. There are now 16 STATES representing 28.3% of the population included, with a weighted average requested rate hike of up to 13.3% with a PARTIAL Trump/GOP sabotage effect or 31.8% WITH the Trump/GOP Sabotage Tax included.

UPATE 7/6/17: GEORGIA ADDED: There are now 17 STATES representing 31.9% of the population included, with a weighted average requested rate hike of up to 15.1% with a PARTIAL Trump/GOP Sabotage Tax or 34.2% with the FULL Trump/GOP Sabotage Tax included.

UPDATE 7/7/17: RHODE ISLAND ADDED: There are now 18 STATES representing 32.2% of the population included, with a weighted average requested rate hike of up to 15.1% with a PARTIAL Trump/GOP Sabotage Tax or 34.1% with the FULL Trump/GOP Sabotage Tax included:

UPDATE 7/12/17: MONTANA and NEW MEXICO ADDED: There are now 20 STATES representing 33% of the population included, with a weighted average requested rate hike of up to 15.1% with a PARTIAL Trump/GOP Sabotage Tax, or 34.2% with the FULL Trump/GOP Sabotage Tax included:

UPDATE 7/14/17: MICHIGAN UPDATED, COLORADO ADDED: There are now 21 STATES representing 34.7% of the population included, with a weighted average requested rate hike of up to 15.0% with a PARTIAL Trump/GOP Sabotage Tax, or 33.7% with the FULL Trump/GOP Sabotage Tax included:

UPDATE 8/1/17: After a long dry spell stretching over the insane Senate "repeal/replace" brouhaha, the rate filings are back with a vengence: I've added IDAHO (complete), ARIZONA (Blue Cross only) MINNESOTA (rough estimates) and the Big One: CALIFORNIA. I've now tracked 25 STATES representing 51% of the population, with weighted average requested rate hikes of up to 13.4% with NO or PARTIAL Trump/GOP sabotage tax included, or 28.2% with the FULL sabotage tax included:

UPDATE 8/1/17: Well, the floodgates have really opened up today (especially with RateReview.HealthCare.Gov being loaded up for 2018). I've also added ALABAMA, ALASKA and WYOMING. Across 28 states representing I've now tracked 28 STATES representing 53% of the population, with weighted average requested rate hikes of up to 13.2% with NO or PARTIAL Trump/GOP sabotage included, or around 28.1% with the FULL sabotage tax:

UPDATE 8/2/17: The flood continues...I've updated 2 states (Minnesota and North Carolina), while also adding two new ones (ARKANSAS and KENTUCKY). I've now tracked the rate requests for 30 STATES representing 55% of the population. The weighted average rate hike request now stands at 12.8% with NO/PARTIAL Trump/GOP sabotage or 27.5% with FULL Trump/GOP sabotage.

UPDATE 8/3/17: Added WEST VIRGINIA and another Big One: TEXAS. I've now compiled rate request data for 32 STATES representing 65% of the population, As I expected, just as California pulled the national average down several points, Texas has bumped it back up again: The weighted average rate hike request now stands at 13.9% with NO or PARTIAL Trump/GOP sabotage, or around 28.2% with FULL sabotage:

UPDATE 8/3/17: Two updates in one day! I've added HAWAII and ILLINOIS. I've now compiled rate request data for 34 STATES representing 68.5% of the population. The weighted average now stands at 13.8% with NO or PARTIAL sabotage or around 27.9% with FULL sabotage:

UPDATE 8/7/17: MORE states added: LOUISIANA, MASSACHUSETTS, MISSISSIPPI, NEBRASKA, NEW HAMPSHIRE and SOUTH DAKOTA. I've now compiled rate request data for 40 STATES representing nearly 75% of the population. The weighted average still stands at 13.8% with No/Partial sabotage, but the FULL sabotage average has inched up to 28.0%.

UPDATE 8/10/17: Coming into the home stretch. I've added seven more states: FLORIDA, NEW JERSEY, NORTH DAKOTA, OHIO, OKLAHOMA, SOUTH CAROLINA and WISCONSIN. I've now completed rate request data for 46 states (+DC) representing over 95% of the total population. The weighted average now stands at 14.4% assuming No/Partial Sabotage, or 29.0% assuming FULL Sabotage.

I hope to plug in the final 4 states (Kansas, Missouri, Nevada and Utah) ASAP, but they're unlikely to move the needle by much given that they collectively only make up 5% of the total population.

UPDATE 8/14/17: I've started going back and updating/correcting/revising the earlier states, where some carriers have either dropped out, expanded coverage or resubmitted revised filings. So far I've updated Virginia, Maryland, Connecticut, Vermont and Oregon. This has bumped the PARTIAL Sabotage average up by nearly 1 full point, and the FULL Sabotage average up by about 0.5 points:

As noted in the Virginia and Maryland updates, I've started going through the earlier state rate filings and revising them to include:

  • Updated/revised carrier rate filings;
  • Additional market withdrawls and/or expansions;
  • Corrections to CSR factor impact, etc.

The original versions of each state writeup includes screen shots of the actual filing documents and explainers behind specific requests; I don't have time for that with most of the updates, so I'm bundling several states together. Here's Connecticut, Oregon and Vermont's revisions:

As noted the other day, now that I've compiled the initial 2018 rate filing requests for 46 states + DC (the remaining 4 states aren't public yet), it's time to go back to the earlier states I analyzed and see whether there's been any updates/corrections to my original estimates. I started running the numbers back in early May, and a lot has changed since then, with carriers dropping out of the exchanges, expanding to fill the gaps or simply refiling with revised pricing requests.

Maryland was the second state I analyzed; I originally came up with the following average:

For the past two years, Virginia has been the first state in the nation to post their initial rate filings for the following year. I originally compiled their individual market 2018 change requests back in early May, and came up with the following at the time:

UnitedHealthcare had previously announced they were dropping out of Virginia, but I didn't have an enrollee number for them, and Aetna had also just announced their withdrawl from the state. I hadn't yet finalized my "CSR/Mandate Penalty" factor layout yet; at the time I assumed the 30.6% weighted average requested assumed full CSR/mandate sabotage and reduced that number by 17 points based on the Kaiser Family Foundation's "19% national average CSR rate hike" estimate analysis, which estimated the CSR impact at 17 points for Virginia.

Regular readers know that I've spent the past 4 months painstakingly tracking and analyzing the 2018 individual market rate filings for pretty much every insurance carrier in every state across the country.

I've completed this process for 46 states + DC. I've confirmed (well, really, Louise Norris confirmed for me) that the filing data for the four missing states--Kansas, Missouri, Nevada and Utah--won't be made available publicly for another couple of weeks, which is irritating...but those four states combined only make up about 5% of the total population anyway; unless their average rate increase requests are significantly higher (or lower) than the average of the rest of the states, they aren't gonna move the needle up or down by more than a tenth of a point or so.

Like Wisconsin and Michigan, Ohio has a high number of carriers statewide...although the per-county competition is still lacking in some areas. Even so, their rate hike requests are still pretty high even with CSR payments being made...and dramatically higher if they aren't.

One interesting tidbit: Check out the CareSource filing letter (first one below the table). They don't mention CSRs or mandate enforcement...but they do specify that a full 5 points of their 23.9% increase request is tied to prescription drug inflation (see Shkreli, Martin)...and even more noteworthy, they say that another 5 points is due specifically to "a number of previously [Medicaid-] qualified individuals" being kicked over to the private exchange, 

I had already posted a partial look at the New Jersey rate hike situation a couple of weeks ago with a video in which Topher Spiro of the Center for American Progress interviewed NJ Congressman Frank Pallone about the situation. Since his comments weren't official and only referred to Horizon Blue Cross, I didn't make it an official part of the Rate Hike spreadsheet, but now I've managed to plug in the remaining carriers and here's how it looks. As expected, with Horizon holding a commanding 70% market share, the statewide average is around 8.5% if CSR payments are made and the mandate is enforced versus 21.6% if CSR payments aren't made and the mandate isn't enforced.

Also, check out Horizon's cover letter explaining the rate hike...they're not screwing around with who to pin the blame on.

North Dakota's numbers are pretty straightforward. Only three carriers, none of whch say anything about CSR or mandate concerns, so I have to assume that their requested rate increases are the best-case scenario. In addition, the KFF estimates suggest only a 5 point additional CSR factor anyway. This results in roughly a 23% average hike if CSRs are paid vs. a 28% increase if they aren't.

Last year, Blue Cross Blue Shield of Oklahoma, as the only carrier participating on the ACA exchange in the state, jacked up their premiums by a jaw-dropping 76%. This resulted in the highest statewide average rate hike in the country of 71% overall.

Well, that certainly seems to have done the trick: This year BCBSOK (still the only on-exchange player and holding over 99% of the market anyway) is requesting a (relatively) modest 8.3% average rate increase...and their filing specifically calls out both the CSR and mandate enforcement factors as being major reasons. Assuming the Kaiser Family Foundation's estimates are accurate, that means that if the CSR payments were guaranteed for 2018, BCBSOK should actually be lowering their rates slightly, to the tune of around 2.4%.

Adding in the steep hikes from off-exchange only CommunityCare (which only has 1,400 enrollees) brings the averages in at a 1.9% rate drop if CSRs are paid, and an 8.7% increase if they aren't.

The good news is that Wisconsin has one of the most robust and competitive exchange markets in the country. The bad news is that, contrary to popular opinion, "competition" doesn't by itself magically lower prices, at least not by enough. Both Anthem and Molina are leaving the ACA exchange (although Anthem is technically sticking around off-exchange), but there's over a dozen other carriers still duking it out.

According to the 11 carriers I have enrollment numbers for, the statewide average rate increase being requested is around 20.8% assuming CSR payments are made; using the Kaiser Family Foundation estimates, that translates into roughly 32.4% assuming they aren't made. Unfortunately, I can't seem to dig up the enrollment data for four carriers: Aspirus, Compcare, Wisconsin Physician Service and WPS (I think the last two are actually subsidiaries fo the same company). Wisconsin's total individual market should be roughly 280,000 people, and when you add up all the numbers I have (including Anthem/Molina) it only comes to around 180,000, so there appear to be roughly 100,000 enrollees missing among those 4 carriers, or over 35%.

I admit to being a bit confused about the distinction between BCBSSC and BlueChoice HealthPlan, which is also a BCBS carrier...I'm guessing one is for HMOs, the other for PPOs or something. In any event, BlueChoice plans appear to only be available off-exchange, and are thus not subject to the CSR issue. BCBSSC is, however, and the Kaiser Family Foundation estimates that their Silver plans would have to go up 23% if CSR payments are cut off. 87%% of SC exchange enrollees are on Silver plans, so that should be roughly 20.2% across all policies.

If CSR payments are made, South Carolina is looking at around a 13.2% average rate hikes; if they aren't, it's an uglier 32.5%.

We're heading into the home stretch now, with the only remaining "supersize" state, FLORIDA. FL has the largest exchange-based individual market enrollment, and the 2nd largest total individual market enrollment of any state in the country, surpassing California for a variety of local economic/demographic reasons. The Kaiser Family Foundation estimates that FL carriers would have to add about 25% to their Silver plan premiums in order to make up for CSR reimbursements if Trump pulls the plug and/or Congress doesn't formally appropriate them. Since 80% of FL exchange enrollees are on Silver plans, that translates to roughly a 20% additional "Trump Tax" for the CSR factor alone. Note that while none of the carriers mention the CSR issue (meaning they all assume the payments will be made), Molina does call out the individual mandate enforcement issues as being part of their 37.5% rate increase request. Unfortunately, they don't put a hard number on this.

New Hampshire's a bit of a head-scratcher this year: Of the three carriers on the individual exchange next year (each of whcih has a significant chunk of the market), Centene is requesting virtually no rate increases whatsoever...while the other two are asking to raise their rates by over 40% apiece.

Even more odd: Harvard Pilgrim's 42.5% seems to assume the worst regarding CSRs/mandate enforcement...yet Matthew Thornton (BCBS) is asking for 45.3% while assuming CSRs will be paid.

Finally, Kaiser assumes around a 10% Silver rate increase in NH if CSRs aren't paid, which translates into about 5.6% spread across the entire membership. Result: 29.1% if CSRs are paid, 34.7% if they aren't.

With Blue Cross Blue Shield of Nebraska declining to participate in the Nebraska exchange, that leaves just Medica as the sole individual market carrier. They're asking for a 16.9% average rate hike, 

Interestingly, while Medica's rate filing letter clearly states that the 16.9% request assumes CSR payments will be made and the mandate will be enforced, they also list "unprecedented uncertainty/risk inherent in the marketplace" as one of the key drivers of the increase.

The Kaiser Family Foundation estimates the CSR issue as adding around 15% to NE Silver plans, which translates into roughly a 10% additional increase if spread across all polices, or 26.9% overall.

There's only two carriers participating in Mississippi's individual market next year (plus Freedom Life, which once again is just a shell company here). They're asking for 16.1% average rate hikes, and since there's no mention in any of the filings about CSR payments not being made or the mandate not being enforced, I'm assuming that increase doesn't account for those factors.

The Kaiser Family Foundation estimates MS carriers would have to jack up Silver plans by a whopping 27% to cover lost CSR reimbursements. 87% of MS exchange enrollees receive CSR help, so that amounts to a stunning 23.5% average rate hike if spread across all individual policies. As a result, assuming they aren't made, I estimate Mississippi's average rate increase would be an ugly 39.6%.

Massachusetts has one of the stablest statewide insurance markets, no doubt in large part due to their having instituted the precursor to the ACA, "RomneyCare", 4 years earlier. Massachusetts also merged their small business and individual market risk pools, which helps stabilize things. As a result, they have a high number of carriers participating in their ACA exchange and are among the few states with single-digit average rate hikes...assuming CSR payments are forthcoming and the individual mandate is properly enforced.

Assuming CSR payments aren't made, I used the Kaiser Family Foundation's 19% average estimate for Silver plan hikes due to the CSR factor. Since a whopping 92% of MA's exchange enrollees chose Silver plans (it looks like MA's unique "ConnectorCare" plans are considered Silver as well), that means an average CSR factor of around 17.5 points across the entire individual market.

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