2020 Rate Changes

Every year, I spend months painstakingly tracking every insurance carrier rate filing for the following year to determine just how much average insurance policy premiums on the individual market are projected to increase or decrease.

Carriers jump in and out of the market, their tendency repeatedly revise their requests, and the confusing blizzard of actual filing forms which sometimes make it next to impossible to find the specific data I need. The actual data I need to compile my estimates are actually fairly simple, however. I really only need three pieces of information for each carrier:

  • How many effectuated enrollees they have enrolled in ACA-compliant individual market policies;
  • What their average projected premium rate increase (or decrease) is for those enrollees (assuming 100% of them renew their existing policies, of course); and
  • Ideally, a breakout of the reasons behind those rate changes, since there's usually more than one.
  • In 2015, I projected that the overall average rate increases for 2016 would be roughly 12-13% nationally. It turned out to be around 11.6%.
  • In 2016, I projected that the overall average rate increases for 2017 would be roughly 25% nationally. It turned out to be around 22%, but that only included on-exchange Silver plan enrollees across 44 states (I included all metal levels, both on and off exchange, across all 50 states).
  • In 2017, I projected that the overall average rate increases for 2018 would be around 29% nationally, and that 60% of that would be due specifically to deliberate Trump Administration actions designed to sabotage the ACA markets. It turned out to be around 28% nationally.
  • In 2018, I projected that the overall average rate increases for 2019 would be around 2.8% nationally, and that premiums would have dropped around 5.4% on average if not for the ACA's individual mandate being repealed & short-term & association plans being expanded. Hhealthcare think tank Avalere Health came to almost the exact same estimates on the actual rate changes, while Brookings Institute healthcare analyst Matthew Fiedler concluded that unsubsidized ACA individual market premiums would indeed have dropped by around 4.3% nationally on average in the absence of mandate repeal and expansion of #ShortAssPlans.

In other words, I've had a pretty good track record of accurately projecting average premium increases for the upcoming year for four years in a row. With that in mind, below you'll find a table tracking the state-by-state preliminary and final rate changes for the 2020 ACA-compliant individual (and sometimes small group) markets. Scroll down for individual state entry links.

Back in June, the New Mexico Insurance Dept. posted the preliminary 2020 rate change filings for the ACA individual and small group markets. At the time, the vcarriers were requesting the highest average premium increase in the country for next year: An increase of 13.0%.

The main source of this double-digit hike was New Mexico Health Connections, one of just a handful of original ACA Co-Op carriers to survive. They were requesting a whopping 30% average rate hike for 2020, and with over 1/3 of the market share, this was more than enough to drag the statewide average up. A second carrier, Presbyterian, only sells off-exchange but was requesting a 16.3% increase which also pushed the average up.

Well, today the approved rate filings have been released, and there's several eyebrow-raising developments.

First of all, there's this (first noted by Sabrina Corlette):

CHRISTUS HEALTH PLAN LOSES QUALIFIED HEALTH PLAN STATUS

Over the weekend, the New York Department of Financial Services issued a press release announcing approved 2020 ACA-compliant Individual and Small Group premium rate changes:

DFS ANNOUNCES 2020 PREMIUM RATES: LOWERS OVERALL REQUESTED RATES FOR INDIVIDUALS AND SMALL BUSINESSES TO PROTECT CONSUMERS AND FUEL A COMPETITIVE HEALTH INSURANCE MARKETPLACE

I've finally analyzed and posted my 2020 premium rate filing analyses for all 50 states (+DC), so this seems like a good time to take a look at the big picture. The table below summarizes the preliminary filings for every state, with four exceptions where the approved (or at least mostly-approved, in the case of Oregon) average rate changes are listed. Nationally, it looks like insurance carriers are only requesting an average premium increase of about 0.6% for the ACA-compliant individual market in 2020. A few caveats:

Vermont is the fourth state to announce their approved 2020 ACA individual/small group market premium rate changes. VT (along with Massachusetts and DC) has (wisely, in my opinion) merged the risk pools for the two markets into one, meaning I have to plug the numbers in differently on my spreadsheet.

Back in mid-May, my initial analysis of the two carriers participating in both Vermont markets put the weighted average rate increase being requested at an even 13.0% statewide: Blue Cross Blue Shield of VT was requesting a 15.6% increase, while MVP Health Care asked for a 9.4% bump.

From the Green Mountain Care Board a few days ago:

GREEN MOUNTAIN CARE BOARD MODIFIES AND APPROVES RATE REQUESTS FOR 2020 VHC PLANS

Back on May 31st, I reported that New York's Dept. of Financial Services had released the preliminary, requested premium rate hikes for the 2020 ACA individual and small group markets. At the time, the weighted average increase requested state-wide was around 8.4% (although I got 8.3% when I plugged the hard enrollment numbers into a spreadsheet).

For the small grouip market, NY DFS reported an average requested increase of 12.0%, although again, I only got 11.3% when I plugged in the numbers.

Yesterday, however, NY DFS became the third state (after Oregon and Virginia) to publicly release their approved 2020 premium changes...and like OR & VA, they've shaved a few points off the average rates:

DFS ANNOUNCES 2020 PREMIUM RATES: LOWERS OVERALL REQUESTED RATES FOR INDIVIDUALS AND SMALL BUSINESSES TO PROTECT CONSUMERS AND FUEL A COMPETITIVE HEALTH INSURANCE MARKETPLACE

At long last, I've completed my analysis of the preliminary 2020 rate filings for ACA-compliant individual market policies across all 50 states (+DC)! in most cases I've also included the small group market, although with far less documentation for those.

Texas, understandably enough, has the third largest individual market in the country after California and Florida, at somewhere around 1.27 million enrollees (they had around 990,000 on-exchange enrollees; I'm pretty sure around 75% of the market is on-exchange these days).

There's ten carriers offering ACA policies on the individual market in Texas, and fifteen participating in the small group market. Unfortunately, most of the rate filings are redacted or missing data altogether (again), so I was only able to cobble together hard enrollment data for half the Indy market carriers, comprising just 15% of the statewide market. I've run an unweighted average for the other five carriers, and blended that with the first five for a semi-weighted average rate hike of just 0.8% overall.

I know this is an imperfect way of doing it, but it's the best I can do at the moment. I hope to have more complete data once the approved filings are made available.

New Jersey is an important state to watch, as they (along with DC) are the first state to specifically reinstate the ACA individual mandate penalty at the exact same levels as the just-zeroed out federal version. Massachusetts has a mandate penalty in place this year as well, but a) theirs pre-dated the ACA and was simply dusted off again and b) theirs uses a different formula anyway.

Last year, Individual Market insurance carriers in New Jersey announced that average unsubsidized 2019 premiums would be reduced by an average of 9.3% statewide due to two laws put into place by the state legislature and Governor Murphy: Reinstatement of the mandate penalty at federal levels (which lowered rates by 6.8 percentage points from +12.6% to just +5.8%) and the initiation of a solid reinsurance waiver program (which reduced rates by a further 15.1 points, for a final average change of -9.3%).

Unfortunately, North Dakota is another state where the carriers have redacted their rate filings. I was able to garner some info about one of the three carriers participating in the Individual Market next year: Medica's filing redaction wasn't done properly, so I was able to extract that they're looking at medical trend of 7.7%, a morbidity reduction of 1.5%, a 2.3% increase due to the reinstatement of the ACA's insurer fee...and a 20% reduction due to the implementation of the state's reinsurance program, which I first reported on last fall and followed up with this spring.

Sure enough, a week or so ago it was made official:

(sigh) I'm into the home stretch with only a handful of states left to go. Unfortunately, South Carolina is yet another state where the actual enrollment numbers are either missing or redacted, making it impossible to run a properly weighted average...but again, the range between the three carriers offering individual market policies is so narrow that it doesn't make much difference anyway (between -3.72% and +0.17%).

The unweighted average is a 1.9% reduction in unsubsidized premiums statewide.

On the small group market, however, average 2020 premiums are jumping by double digits: 11.1%.

Oklahoma has three carriers on the Individual Market these days. Once again, all three rate filing memos are redacted, but I was able to dig up the number of current policy holders for one of them (CommunityCare HMO).

I've bumped that number up a bit to account for the total number of covered lives to an even 2,000. For the other two carriers, I'm assuming Blue Cross Blue Shield still holds the lion's share of enrollees and that the total on+off-exchange market is around 187,000 people.

If this is all correct, the weighted average rate increase for unsubsidized enrollees is around 1.4% statewide.

Meanwhile, the unweighted average rate hike for the small group market is 6.5%.

Not much to say about Mississippi this year...they still have two carriers on the individual market, and while they do have a whole website/database set up specifically to track and report health insurance premium changes, it's messy and only appears to post the rate filings after they've been approved, which won't be for another couple of months.

As a result, I have no idea what the relative market share is between the two and am assuming they're roughly even. Even if they aren't, the requested rate changes are so close it doesn't make much difference anyway (2.3% and 3.0%). If approved as is, unsubsidized Mississippians can expect to pay about $200 more total next year.

On the small group market, there's five carriers; again, I don't know the market share of any of them, so the unweighted average increase is 6.2% statewide.

Massachusetts, which is arguably the original birthplace of the ACA depending on your point of view (the general "3-legged stool" structure originated here, but the ACA itself also has a lot of other provisions which are quite different), has ten different carriers participating in the individual market. MA (along with Vermont and the District of Columbia) has merged their Individual and Small Group risk pools for premium setting purposes, so I'm not bothering breaking out the small group market in this case.

Getting a weighted average was a bit tricky. On the one hand, only one or two of the rate filings included actual enrollment data. On the other hand, the Massachusetts Health Connector puts out monthly enrollment reports which do break out the on-exchange numbers by carrier. This allowed me to run a rough breakout of on-exchange MA enrollment. I don't know whether the off-exchange portion has a similar ratio, but I have to assume it does for the moment.

Huh. This is interesting...after a couple dozen states with near-flat or even reduced 2020 premiums, Louisiana is just the third state I've come across where the carriers are seeking double-digit rate increases for next year.

There's actually only 3 carriers offering individual market plans in Louisiana, but there's seven listings because two of the carriers have broken out their submissions into several different product lines. Overall, HMO LA, LA Health Service & Indemnity (Blue Cross Blue Shield of LA) and Vantage Health Plan are requesting average premium increases of 11.7% statewide.

I should note that there's also one odd listing (see second screenshot below), from UnitedHealthcare. It claims to be for off-exchange ACA-compliant individual market plans, but two things about it make no sense:

After several years with four carriers participating in their ACA individual market, the Peach State is gaining not one but two additional carriers this year: CareSource and Oscar are joining Alliant, Ambetter/Centene, Blue Cross Blue Shield and Kaiser. Unlike a lot of the states I've crunched numbers for recently, I was able to acquire hard enrollment numbers for every single Georgia carrier...including both the Individual and Small Group markets, which is a rarity this year!

Statewide, GA's individual market carriers are requesting average unsubsidized 2020 rate hikes of just 2.4%, while the small group carriers are looking for a 12.8% average increase:

(sigh) The good news is that none of the five carrier rate filings for Utah's individual market have been redacted. Hooray! The bad news is taht only one of the five (Molina) included their current enrollment total on the filing at all. Boo!

As a result, I'm only able to run a "mostly" unweighted average...that is, it's an unweighted average of the other four carriers, plus a slight additional tweak based on the tiny number (448 people) enrolled in Molina policies. Utah's total individual market should be around 240,000 people, so that's barely a rounding error. My best guess is that unsubsidized enrollees are looking at roughly a 5.9% average premium drop next year.

For the state's small group market, the unweighted average increase is 2.7%.

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