2021 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 tendency to jump in and out of the market, repeatedly revise their requests, and the confusing blizzard of actual filing forms 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nationally, and that premiums would have dropped around 5.4% on average if not for the ACA's individual mandate being repealed & short-term & association plans being expanded.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 five 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 2021 ACA-compliant individual (and sometimes small group) markets. Scroll down for individual state entry links.

For 2021, the biggest new factor is, of course, the impact of the COVID-19 pandemic on both 2020 and 2021 medical claims expenses. I've added a new column which attempts to separate that out, though not every carrier does so, while some simply refer to the impact of COVID-19 in a fairly vague way.

(click image for higher-resolution version)

The good news is that the federal Rate Review database has now posted the preliminary avg. 2021 rate filings for the individual and small group markets for every state. This makes it very easy to plug in the average requested rate changes in 2021 for every carrier participating in both markets.

The bad news is that most of the underlying filing forms are heavily redacted, meaning I can't use the RR database to acquire the other critical data I need in order to run a proper weighted average: The number of people actually enrolled in the policies for each carrier.

This means that in cases where this data isn't available elsewhere (either the state's insurance department website, the SERFF database or otherwise), I'm limited to running an unweighted average. This can make a huge difference...if one carrier is requesting a 10% increase and the other is keeping prices flat, that's a 5.0% unweighted average rate hike...but if the first carrier has 99,000 enrollees and the second only has 1,000, that means the weighted average is actually 9.9%.

via the New Hampshire Insurance Dept:

Large Decreases in 2021 Premium Rates Expected in Individual Market

CONCORD, NH – The federal government has published information on proposed rates for New Hampshire’s health insurance exchange (https://ratereview.healthcare.gov/) in 2021.

The New Hampshire Insurance Department is reviewing 2021 forms and rates for individual health plans. For 2020, the second lowest cost silver plan was $404.60. The 2021 second lowest cost silver plan proposed premium rate is $318.95. This represents a 21.2% decrease.

It's important to note that the 21.2% decrease only refers to the difference between the 2020 benchmark and the 2021 benchmark plans. They aren't necessarily from the same carrier, and even if they are, that's not the same as the weighted average rate changes for all policies at all metal levels from all carriers.

Back in late June, I noted that the Maine Insurance Dept. had issued the preliminary 2021 rate filings for the state's individual and small group market carriers. At the time, the individual market carriers were averaging rate reductions of around 4% while the small group carriers were looking to raise premiums by around 6.2%.

It was recently brought to my attention that revised rate filings have been submitted by Maine carriers for 2021...and while these still aren't the final/approved rates, they're significantly lower than the original filings.

Two of the three indy market carriers (Anthem and Harvard Pilgrim) have reduced their rates dramatically. The third (CHO) only reduced theirs by a couple of points, but the net result is that they're now averaging a 13% reduction...9 points lower than the 4 points they were already being knocked down.

The small group market carriers didnt' change their requests by as much, but they're still lower: A 4.4% average increase instead of 6.2%.

Virginia is usually the first state to publicly post their preliminary annual individual/small group market health insurance premium rate filings; historically they've published them as early as mid-April. This year, however, due primarily to the COVID-19 pandemic, I presume, they didn't actually post them until mid-August.

The average premium changes for 2021 on the individual market range from a 13% drop to a 7.7% increase, with the statewide weighted average coming in at around a 7.2% reduction. For the small group market, premiums are increasing by around 3.6% on average, ranging from a 2.4% drop to a 10.9% increase.

Two other noteworthy items: First, Optimum Choice is expanding into VA's individual market (this isn't the same as Optima Health); secondly, VA's indy market has dropped from over 300,000 last year to around 256,000 this year, presumably due to the lingering effects of Medicaid expansion enrollees shifting over from subsidized private plans.

The Delaware Insurance Dept. has posted the preliminary 2021 rate filings for the individual and small group health insurance markets.

The Indy market is about as simple as it gets since there's only a single carrier offering ACA policies either on- or off-exchange (Highmark BCBS). They're actually cutting premiums on average slightly next year, by half a percent. They state in their summary that "Covid19 is expected to increase claim costs in 2021"...but that's all they have to say about it. The full actuarial memo includes an extensive section about the COVID-19 impact factor...but the numbers/percentages are all redacted:

The Idaho Insurance Dept. has posted the preliminary rate filings for the 2021 Individual and Small Group markets:

The Department of Insurance receives preliminary health plan information for the following year from insurance carriers by June 1 and reviews the proposed plan documents and rates for compliance with Idaho and federal regulations. The Department of Insurance does not have the authority to set or establish insurance rates, but it does have the authority to deem rate increases submitted by insurance companies as reasonable or unreasonable. After the review and negotiation process, the carriers submit their final rate increase information. The public is invited to provide comments on the rate changes. Please send any comments to Idaho Department of Insurance.

Way back in May (a lifetime ago), Vermont was among the first states to publicly post their preliminary 2021 rate filings for their combined individual & small group market. At the time, the carriers were requesting an average 6.8% rate increase, and noted that they had no clue how much to tack on to cover themselves for the COVID-19 factor...or to even reduce rates because of it.

This week, the Vermont insurance regulatory board issued their final decisions about both BCBS of Vermont and MVP Health Plan, and cut down on each of their requested increases by several points (h/t Louise Norris for the links):

Hmmm...back in June, the New York Dept. of Financial Services published the preliminary 2021 rate filing requests for the individual & small group markets. As I noted at the time:

Hmmmm....some of these seem suspiciously high, at least as compared to the handful of other states which have released their preliminary requests so far, but we'll have to see...

Well, today the NY DFS issued the approved 2021 rates for both markets, and sure enough, they've been reduced pretty significantly:

DFS ANNOUNCES 2021 HEALTH INSURANCE PREMIUM RATES, PROTECTING CONSUMERS DURING COVID-19 PANDEMIC

It was just a few weeks ago that the Montana Insurance Department posted the preliminary 2021 rate filings for the individual & small group markets. At the time, the individual market carriers were requesting a 3.2% average rate increase, while the small group carriers wanted a 2.4% bump.

Unfortunately, the actual actuarial filing memos ("Part II Justification") weren't available as of this writing, so I couldn't tell whether there's any COVID-19 impact specifically mentioned or not. Montana is one of the states with the fewest casese of COVID per capita, so I wasn't expecting much, but it would be nice to know.

Today I checked again and it looks like they've not only posted the Actuarial Memos (which don't mention COVID-19 at all, as I expected), but it also looks like Montana is the first state to publish their final/approved 2021 rate changes as well. They also modified the estimated enrollment numbers somewhat. Here's what it looks like now:

The bad news is that I still can't find any official 2021 rate filings at the Alabama Insurance Dept. website.

The good news is that both of last years' individual market carriers (Blue Cross Blue Shield and Bright Healthcare) do have listings for 2021 in the SERFF database.

The bad news is that those listings don't include actual rate filings, just some other forms.

The good news is that rate filings for every state appear to be available at RateReview.HealthCare.Gov this week.

The bad news is that the filings at RR.HC.gov appear to be incomplete so far; BCBS is listed but Bright isn't (and since I do have other forms for Bright being listed in 2021, I'm pretty sure it's not because they're pulling out of the Alabama market).

The North Carolina Insurance Dept. has published a summary of the preliminary premium rate changes requested by insurance carriers for the indvidual and small group markets in 2021.

The good news is they include the number of people enrolled by each carrier in both markets, making it easy to calculate a weighted average, and th ey even include the SERFF tracking number for each.

The bad news is they don't include links to the actuarial memos, and even plugging the tracking numbers into the SERFF database only brings up the memos for three of the six carriers on the individual market...and of those, two of the three have been redacted (Oscar and Cigna), while the third (UnitedHealthcare) is brand-new to the North Carolina market anyway and therefore has no COVID-19 impact on their rate changes to speak of.

As I noted last year, the Nevada Insurance Dept. website is both helpful and frustrating when it comes to tracking down the type of data that I need. On the one hand they make it very easy to view the individual & small group market rate filing summaries: Carrier names, markets, sumission dates, status, effective dates and most importantly, the proposed and approved average rate changes are all easily found.

On the other hand, they don't actually link to the filing memos or URRT forms, which means I can't find the actual effectuated enrollment numbers for each carrier, the impact of COVID-19 on each carrier's request or other noteworthy info about the filings. Oddly, they do include the SERFF tracking numbers...except that plugging those into the SERFF database still doesn't bring anything up, which kind of defeats the point.

Fortunately, the NV DOI does provide the weighted average of the entire market and COVID-19 impact elsewhere. I've also been able to piece together the total market enrollment (both on & off-exchange) using some other public data.

I've acquired the preliminary 2021 rate filings for Georgia's individual and small group market carriers. There were two filings submitted for many of the carriers because of a (since delayed) ACA Section 1332 waivier submission; the carriers submitted one in case the waiver was approved and a second if it wasn't. Since the process has been delayed, however, the no-waiver filing is the one which is relevant.

As you can see in the tables at the bottom of this entry, the overall weighted rate change requested by individual market carriers in Georgia is a 1.3% reduction, which would have been more like a 2.3% drop if not for the COVID-19 factor, according to the carriers. The small group market carriers are requesting an 11.1% average increase, which is unusually high these days. I haven't reviewed all the memos for the sm. group market to see what they're pinning on COVID-19, however.

Here's what the indy market carriers have to say about the COVID-19 factor in their 2021 filings:

ALLIANT (indy):

Yesterday the Pennsylvania Insurance Dept. posted the preliminary 2021 rate filings for the individual and small group markets. On the surface, it appears that Pennsylvania has an absurdly competitive market, with 17 carriers listed on the indy market and 21 small group carriers...but when you look closer, many of these are simply branches of the same main company.

For instance, fully five of the individual market carriers are variants of "Highmark"...which is actually Pennsylvania's rebranding of Blue Cross Blue Shield. Two are branches of Geisinger and another two are both UPMC. The same is true in the small group market.

And don't even get me started about "Capital Advantage Assurance Company" and "Capital Advantage Insurance Company". Sheesh.

In any event, the overall rate filings average out to rougly a 2.6% premium decrease on the individual market and a 2.3% increase for small group plans, when weighted by carrier market share.

The Kentucky Insurance Dept. has posted KY's preliminary 2021 rate filings for the individual and small group markets, and the requested average rate increases for both are unusually high compared to the other states which have submitted their filings so far. In another unusual development, most of the carriers on each market are being pretty specific about the impact (or lack thereof) on their 2021 rate filings from the COVID-19 pandemic (I only have UnitedHealthcare posted once but they account for three of the seven small group carriers listed.

Anthem Health Plans of KY (individual market):

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