END OF 2018 OPEN ENROLLMENT PERIOD (42 states)

Time: D H M S

2018 Rate Hikes

The 2018 Rate Hike Project: (SCROLL DOWN FOR CHARTS/TABLES)

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:

UPDATE 8/20/17: More updates/corrections, to Maine and the District of Columbia. The averages now stand at 15.4% assuming No/Partial Sabotage or 29.5% assuming FULL Sabotage.

UPDATE 8/23/17: New York has posted their approved average rate hikes, making them the 2nd state to do so after Oregon. I'll start posting revised tables including approved increases as soon as a few more state regulators chime in.

UPDATE 9/01/17: Maryland has posted their approved average rate hikes, making them the 3rd state to do so. In addition, Missouri has finally posted their requested rate increases, so I now have compiled requested increases for 47 states +DC and approved increases for 3 states:

UPDATE 9/06/17: I've finally plugged in the requested rate hikes for the final 4 states (Kansas, Missouri, Nevada and Utah)! Note that Kansas is highly questionable, as I only have data for 1 of the 2 carriers participating, and the missing one has most of the market share. I've also gone back and cleaned up a couple of other states with some minor corrections (I had forgotten that VT, DC and MA all merged their individual and small group market risk pools, meaning the CSR factor is lower in each than I had previously estimated). In addition, with four states having released approved rate changes (Oregon, Maryland, New York and now Vermont), I've overhauled the spreadsheets to start including the columns for APPROVED rate changes.

UPDATE 9/06/17 (busy day!): Two more states have released their APPROVED rate hikes (Maine and Colorado). In both cases, one of my assumptions regarding the requested increases turned out to be wrong, so I have do go back and revise those as well. This has resulted in the "No/Partial Trump Tax" average inching its way over the 16% line for the first time (16.1%, actually), and has the "FULL Trump Tax" average hovering very close to the 30% mark.

With approved rates for 6 states now baked in, the "partial sabotage" average stands at 19.4% while the "full sabotage" average is 24.1%...several points higher and lower respectively, with CSR sabotage "only" accounting for about 20% of the average increase. However, it's very important to remember that these states only represent about 9% of the total population; both numbers will almost certainly jump around quite a bit as more states are added to the mix, just as they did when I started adding requested rate changes in.

UPDATE 9/7/17: Bad news out of Virginia and Kentucky; Optima Health is pulling out of a bunch of VA counties and the carriers have all submitted revised "NO CSR!" filings which are generally even higher than the Kaiser Family Foundation had estimated for the state. In addition to opening up the "bare county" problem again, this also had the effect of bumping up both the "partial" and "full" sabotage averages a bit, to 16.2% and 29.8% respectively. Meanwhile, in Kentucky, Anthem is similarly pulling out of about half the state, meaning perhaps 35K enrollees will have to switch plans. This ironically reduces the "average increase" in the state slightly.

UPDATE 9/14/17: Added approved rates in Connecticut, Louisiana and Michigan (MI's aren't officially approved but appear unlikely to change much). I now have approved rates for 9 states.

UPDATE 9/27/17: No updates for awhile due to the Graham-Cassidy brouhaha, but with that out of the way and the final 2018 enrollment period contract signing deadling set for tomorrow, several more states have come out with their final, approved rate changes, including Florida, Washington State, Virginia, South Carolina and Mississippi. I now have final rate changes for 14 states representing around 1/3 of the country.

UPDATE 10/01/17: Now that we're past the contract signing deadline (with CSR reimbursements pretty much certain not to be guaranteed next year), the approved rates are popping up pretty quickly: I've added Alaska, Arkansas, Idaho, North Dakota and Tennessee.

UPDATE 10/03/17: I've added two more states today: Minnesota and Arizona. This brings the table up to 22 states representing around 43% of the country.

UPDATE 10/04/17: I've added New Mexico this morning (the numbers are a bit fuzzy but come from the state Insurance Commissioner so should be solid enough to enter).

UPDATE 10/5/17: Thanks to an assist from Protect Our Care, I've managed to plug in the approved rate increases for six more states: Illinois, Indiana, Nevada, Ohio, South Dakota and Utah.

UPDATE 10/5/17: OK, make that seven more today; I've also added Delaware.

UPDATE 10/10/17: I have the approved rates for Kansas, Nebraska and West Virginia, bringing the grand total up to 33 states, but am holding off until I get a few more states added before actually updating the charts/tables below.

UPDATE 10/11/17: BOOM. California has released their statewide weighted average rate increases, both with and without the CSR load. As the largest state in the country, this (along with the small increases from Kansas, Nebraska and West Virginia) brings the total portion of the population represented up to nearly 69% across 34 states.

UPDATE 10/16/17: Pennsylvania has chimed in. That makes 35 sates or 73% of the population accounted for.

UPDATE 10/18/17: Added Montana, North Carolina, North Dakota, Rhode Island and New Jersey. Around 80% of the total population has now been accounted for; the only states left at this point are: Alabama, Hawaii, Iowa, Kentucky, Massachusetts, Missouri, New Hampshire, Oklahoma, Texas, Wisconsin and Wyoming (along with the District of Columbia).

UPDATE 10/24/17: With just a week to go before Open Enrollment begins, I've compiled the approved rate hikes for 3 more states (and the District of Columbia): Kentucky, Massachusetts, Wisconsin. That's 85% of the country accounted for. Eight states left to go.

UPDATE 10/27/17: Just 5 days to go before Open Enrollment begins. I've plugged in the approved rate hikes for 6 more states, including Alabama, Hawaii, Missouri and Wyoming. This accounts for 90% of the total population, leaving just Texas and New Hampshire to go.

UPDATE 10/17/17: OK, for completeness' sake, I went ahead and filled in New Hampshire and Texas, although I'm still waiting on confirmation for some oddities in each state. Still, overall, this should pretty much complete the picture.

With all of these changes/additions/updates, here's what the overall picture now looks like (click images for full-size versions):

(sigh) Colorado's state insurance division just released their approved 2018 rate increases (busy day!), and the situation appears to be similar to Maine: The average requested rates which I thought already assumed no CSR reimbursements appear to have assumed CSRs would be paid after all:

Division of Insurance approves health insurance premiums for 2018
Commissioner: Measures to stablize market for 2018 must happen by Sept. 30

DENVER (Sept. 6, 2017) – The Colorado Division of Insurance (DOI), part of the Department of Regulatory Agencies (DORA), has approved the individual and small group health insurance plans for 2018. Average premium changes within each market - individual and small group - as well as the average change for each insurance company are listed below.

The state of Maine's insurance regulatory agency has announced the approved 2018 individual market rate hikes for the three carriers operating in the state. Louise Norris beat me to the punch:

Regulators in Maine published rate proposals for the three Maine exchange insurers in June, and finalized the rates in early September. Insurers proposed two sets of rates: one that assumes cost-sharing reduction (CSR) funding will continue, and another that assumes the federal government will not fund CSRs in 2018.

The Maine Bureau of Insurance initially rejected all three insurers’ rate proposals on August 10, and asked them to submit new rates. The revised rate filings were then approved on September 1. These average approved rate increases all assume that CSR funding will continue in 2018:

Vermont was one of the first states I analyzed back in the late spring; obvoiusly a lot has changed since then, so I updated/revised my analysis of their requested rate hikes for 2018 a couple of weeks ago, with requested average increases of 11.9% if CSR payments are made or 21.6% if they aren't.

Yesterday, Louise Norris gave me a heads up that the Vermont regulators have issued their approved rate increases for the two carriers operating on the individual and small group markets in the tiny state. This makes Vermont the 4th state to announce their approved rates for next year, joining Oregon, Maryland and New York.

Nevada is the final state to post their requested rate hikes for 2018 (or at least they're the last one I tracked down, anyway). I've now done at least a rough analysis of all 50 states + DC, and while some of the data is a bit outdated (remember, I started doing this back in late April/early May), most of it should still be fairly close to the present situation...at least in terms of requested rate hikes.

In Nevada, after much concern that a bunch of rural counties wouldn't have any exchange carriers at all, Centene stepped in to cover them. They aren't listed in the table below, but since I believe they're new to the state, that shouldn't matter in terms of rate increases since there's no base rates to compare against anyway.

Utah has also finally released their requested 2018 individual market rate increases. There are six carriers offering individual policies next year, but only 2 of them are participating on the ACA exchange (and the 4 off-exchange carriers hold less than 4% of the total market combined). In fact, two of the off-exchange-only carriers are barely participating at all: BridgeSpan has only 8 enrollees, while "National Foundation" (a "phantom carrier" which also goes by "Freedom Life" in other states) once again supposedly only has a single "enrollee". Molina has a few hundred off-exchange enrollees, but the bulk of their 70,000-person membership are in exchange-based policies, and they're dropping off the exchange next year, so those 70K will have to choose from one of the two remaining exchange carriers: SelectHealth and the University of Utah.

Until recently, my 2018 Rate Hike project was still missing 4 states: Kansas, Missouri, Nevada and Utah. Last week Missouri finally posted their requested rate increases for next year. Today it looks like Kansas has done the same...at least partly.

As I noted back in June, there are 3 carrers on the KS individual market this year: Medica, Blue Cross Blue Shield of Kansas Solutions and Blue Cross Blue Shield of Kansas City. Any confusion between the BCBS names was made moot, however, as BCBS of KC announced they were dropping out of the indy market anyway.

That leaves Medica and BCBSKS, both of whom filed plans to stay on the market...but only Medica appears to have actually submitted rate requests, for a mere 7,600 enrollees:

Thanks to Zach Tracer for the heads up!

My 2018 Rate Hike project petered out a few weeks back with the requested rate increases posted for 46 out of 50 states (along with DC). Unfortunately, the last 4 states (Kansas, Missouri, Nevada and Utah) decided to keep their cards close to their chest, delaying any public viewing of even the requested rate increases for awhile longer.

When I last checked in on Maryland's individual market rate hikes for next year, the picture was pretty grim: Overall requested increases of around 46%...and that assumed that CSR reimbursements are made in 2018. If you assume CSRs aren't paid, it looked even worse: A whopping 57% average increase statewide for unsubsidized enrollees. Ouch.

Today, the Maryland Insurance Dept. issued their approved rate changes for the individual and small group markets...and while they did knock the rate increased down significantly, there's still not much to be cheery about. It also includes a couple of handy additional data points:

The Maryland Insurance Administration Approves Non-Medigap Premium Rates for 2018 Small Group and Individual Markets

Open Enrollment Begins Nov. 1 in the Individual Market; Consumers Encouraged to Shop Rates

File this one under "Be Careful What You Wish For".

Just a couple of days ago I reported that the New York Dept. of Financial Services had issued their approved 2018 rate changes for the 15 insurance carriers participating in the state's individual and small group markets...and, in some welcome news, they whittled down the rate increases by a bit, from 17.7% on average to 14.5% on average in the individual market, and from 11.7% to 9.3% in the small group market.

Then, the very next day, Zach Tracer of Bloomberg News broke this story:

New York State’s biggest hospital system plans to stop selling Obamacare plans, blaming a costly plank of the law and uncertain prospects for a fix amid a wider Washington brawl over health care.

Back in early June, the New York Dept. of Financial Services posted the requested 2018 rate hikes for the individual and small group markets. In most states, the CSR reimbursement issue is a much bigger factor than whether or not the Trump Administration enforces the individual mandate, but in New York it's the exact opposite: According to the NY DFS, loss of CSR payments would only tack on 1.3 points to the total, while "a full repeal of the federal individual mandate would increase rates by an additional 32.6%".

The reason for the fairly nominal CSR factor is that the vast majority of NY's CSR-eligible population (those earning 138-200% FPL) is instead enrolled in the state's Basic Health Program. As a result, only 26% of New York's exchange enrollees receive CSR assistance, and the 200-250% FPL recipients only receive a fairly skimpy amount of CSR help anyway. At the opposite end of the spectrum, the 32-point mandate factor is far higher than most carriers are indicating (more like 4-5 points), but there's a big difference between the administration "not enforcing" the penalty and outright repealing it, which NY DFS is talking about.

In any event, this means that NY's requested average increases boiled down to: 15.0% if CSRs are paid/mandate enforced, 16.6% if CSRs aren't paid/mandate is enforced, or a whopping 50.5% if CSRs aren't paid and the mandate was repealed.

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, 

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