2019 Rate Hikes

2018 MIDTERM ELECTION

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Rhode Island is the 5th state (to my knowledge) to officially post their preliminary 2019 individual market rate change requests.

As shown below, things are pretty cut & dry in Rhode Island; they only have 2 carriers participating in the individual market (Blue Cross Blue Shield and Neighborhood Health Plan). BCBSRI is asking for a 10.7% average increase, while Neighborhood is requesting 8.7% overall.

The estimated market share ratios are based on this press release from HealthSourceRI, the state ACA exchange. That doesn't include the final numbers or the off-exchange enrollment, but it should be pretty close, as there are only 2 carriers and their requested increases are so close to begin with it wouldn't make much difference. The weighted average is 9.3%.

So far, only 4 states have released their preliminary 2019 ACA-compliant individual market premium rate filings: Maryland, Virginia, Vermont and Oregon.

So what's the deal with the other 46 states (+DC)? Well, Louise Norris has sent me the link for this handy 2019 Submission Deadline table from SERFF (the System for Electronic Rates & Forms Filing, a database maintained by the National Association of Insurance Commissioners).

However, it's a bit overly cumbersome for my purposes: It stretches out over 6 full pages, and includes columns for Standalone Dental Plans as well as a bunch of info regarding the Small Group Market. I did used to try tracking Small Group rates as well, but that got to be too difficult to keep up with, and I haven't really done much analysis of standalone dental plans at all. Let's face it: About 90% of the drama, controversy and confusion regarding ACA premiums is all about the individual market.

This just in from the Washington State Insurance Commissioner's office...

Eleven health insurers file for 2019 individual market: No bare counties

May 25, 2018

OLYMPIA, Wash. – Eleven health insurers filed 88 health plans for Washington state’s individual market yesterday, and all 39 counties will be covered in 2019.

The proposed rate changes are not public until 10 days after the OIC has determined the filings are complete. Release of the proposed rate changes is targeted for June 4. 

“We can all breathe a sigh of relief knowing consumers in every county who need coverage will have access to a health plan in 2019,” said Insurance Commissioner Mike Kreidler. “Obviously, how much premiums may change and any increases to out-of-pocket costs are still key concerns, but I’m grateful that we can assure people that coverage is available, regardless of where they live.” 

One of the things Ford had always found hardest to understand about humans was their habit of continually stating and repeating the very very obvious, as in ‘It’s a nice day’, 'You’re very tall’, or 'You seem to have fallen down a thirty-foot well, are you alright?’

--Douglas Adams, The Hitchhiker's Guide to the Galaxy

via Peter Sullivan, The Hill:

A top insurance industry official said Wednesday that he expects “substantial” ObamaCare premium increases for 2019.

Kris Haltmeyer, a vice president at the Blue Cross Blue Shield Association, told reporters that the premium increases were in part due to the repeal of ObamaCare’s individual mandate in the Republican tax reform bill in December. He also cited lawmakers’ failure to pass a bill aimed at lowering premiums, which fell apart earlier this year amid a partisan dispute over abortion restrictions.

It's become a tradition that every spring/summer/fall, I pore over the official SERFF database for every state, furiously searching for the ACA-compliant rate filings for the upcoming year.

The thing is, the SERFF database, in addition to being somewhat confusing and clunky to work with, includes a lot more than just "here's how much we want to raise our rates next year". Even after narrowing it down to just major medical health insurance policies, there are often still dozens of different forms and spreadsheets in the database, covering pretty much any change to any insurance policy for any carrier. If a carrier drops out of a market, there are forms. If they stop offering PPOs, there are forms. If they merge with or buy out another company, there are obviously forms. Even for the rate filings themselves, there are often a dozen or more different PDFs and/or spreadsheets included as supporting documentation.

OK, this doesn't technically count as an official 2019 Rate Hike analysis since none of it comes from actual carrier rate filings, but Covered California, the largest state-based ACA exchange, just released their proposed 2018-2019 annual budget, and it includes detailed projections regarding expected premium increases and enrollment impact over the next few years due specifically to the GOP's repeal of the ACA's Individual Mandate. Oddly, while they mention short-term plan expansion as another potential threat to enrollment/premiums, they do so passingly, and they don't mention association plans at all:

Since 2014, nearly 5 million people have enrolled in Medi-Cal due to the Affordable Care Act expansion, and more than 3.5 million have been insured for some period of time through Covered California. Together, the gains cut the rate of the uninsured in California from 17 percent in 2013 to a historic low of 6.8 percent as of June 2017.

A huge shout-out to Jesse O'Brien for the heads up on this (as well as for posting some of the actual filing data).

Oregon just became the 4th state to submit their preliminary 2019 ACA individual market rate filings, and while the expected increase is smaller than expected on average (in part due to Oregon's strict control of short-term plans), repeal of the individual mandate by Congressional Republicans and Donald Trump are still responsible for the vast majority of the rate increase.

Normally, I don't start posting natoinal projections for my annual Rate Hike Project until I have at least filing data for at least a dozen or so states because the national weighted average jumps around so much early on. A "national average" of, say, 10% based on numbers from, say, Vermont, Wyoming and the District of Columbia (collective population: 1.9 million people) is gonna change radically once you add California or Florida to the mix if they're looking at a 20% hike, for example.

Having said that, seeing how advocacy organization Protect Our Care has decided to launch their own version of my Rate Hike Project, and seeing how I do have preliminary 2019 rate increase projections from at one large state (Virginia) and two mid-sized states (Maryland and Oregon), I've decided to go ahead and start posting the national projections early, with a major caveat that the national average will likely change dramatically until at least 2/3 of the states have been plugged in.

Well. There you have it:

.@SeemaCMS bluntly says the uninsured rate will continue to rise because of rising premiums. "At some point, people can't afford coverage." #PostLive

— Alice Ollstein (@AliceOllstein) May 15, 2018

I think Albert said it best (and it appears to apply to some women as well):

 

For three years now, I've been painstakingly tracking the annual average rate increases for ACA-compliant individual market policies across all 50 states (+DC) and nationally, including both the on & off-exchange markets in as much detail as possible, and at the risk of tooting my own horn too much, my track record on this has been pretty damned accurate:

Given how progressive Vermont is, you'd think that they'd be doing as much as possible to batten down the hatches in order to avoid or mitigate the latest wave of sabotage efforts from the Trump Administration and the GOP...and you'd mostly be correct.

Some of the work on that front has already been done. For one thing, Vermont (along with Massachusetts and the District of Columbia) merges their individual and small group market risk pools together, which helps smooth out premium increases and overall morbidity across a larger risk pool. For another, Vermont has fully embraced ACA provisions such as Medicaid expansion and operating their own full exchange, of course. Vermont, along with a few other states, also has pretty strict rules in place limiting both short-term and association healthcare plans, so that portion of Trump's sabotage attack is neatly cancelled out already.

Hot on the heels of Virginia, Maryland is the 2nd state to post their preliminary 2019 unsubsidized ACA policy rate increase requests. According to Paul Demko of Politico...

Insurers selling Obamacare plans in Maryland are again seeking huge rate increases for 2019, but they could be knocked down significantly by a reinsurance program the state hopes to implement for next year.

CareFirst BlueCross BlueShield wants to increase rates on average by 18.5 percent on its HMO plans, which account for more than half of the individual market this year. Kaiser Permanente, the only other insurer selling on the exchange, is seeking a 37.4 percent average increase on its HMO plans, which cover just over a third of Obamacare customers.

A couple of days ago, I posted that Virginia has become the first state out of the gate with their preliminary 2019 premium rate requests for ACA individual policies. However, I made sure to emphasize that these are preliminary requests only; carriers often resubmit their rate change requests more than once over the course of the summer/fall, and even that may not match whatever the final, approved rate changes are by the state insurance commissioner.

In addition, I generally try to make it understood that there's alotof room for error here--the weighted averages are based on the number of current enrollees, but of course that number can change from month to month as people drop policies or sign up during the off-season (via Special Enrollment Periods). Even then, the rate filing paperwork is often vague or confusing about just how many enrollees they actually have in these plans. Sometimes wonks are reduced to taking the number of "member months" and dividing by 12 to get a rough idea of how many people are enrolled in any given month. Sometimes the only number of enrollees available are from last year, which could bear zero resemblence to how many are currently enrolled. Sometimes the only number available is how many people the carrier expects to enroll in their policies next year. And so on.

IMORTANT UPDATE: As I suspected, it turns out that the stray rate filing posted to the California Insurance Dept. website a few days ago was posted prematurely, doesn't reflect the carrier's final* rate filing, and has since been pulled from the California Insurance Dept. website.

I've been asked to remove the filing data, and seeing how there's nothing nefarious about it (I wasn't "whistleblowing" evidence of anything criminal/unethical), I'm complying with that request. Since everything in the post related to that data, there wasn't much point in keeping the rest of it either.

*(Yes, I'm aware that none of these early filings are "final" since they tend to be revised/resubmitted throughout the summer/fall, but you know what I mean.)

...and to absolutely no one's surprise, GOP sabotage of the ACA will be directly responsible for a significant chunk of the individual market premium increases.

Every year for 3 years running, I've spent the entire spring/summer/early fall 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 going to increase (or, in a few rare instances, actually decrease).

The actual work is difficult due to the ever-changing landscape as 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 easy to find the specific data I need and sometimes make it next to impossible.

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