OE7

Way back in October 2013, the very first official ACA Open Enrollment Period began...and was an immediate disaster for not just the federal exchange website (HealthCare.Gov), but also for about half of the states which were operating their own whole-widget ACA exchange websites.

That first year, there were 15 states doing so: California, Colorado, Connecticut, the District of Columbia (not actually a state, I know), Hawaii, Kentucky, Maryland, Massachusetts, Minnesota, Nevada, New York, Oregon, Rhode Island, Vermont and Washington State. There were oddball problems at launch with most of them, but HI, MD, MA, MN, NV, OR and VT had serious issues.

The Kentucky Insurance Dept. just announced their approved rate changes for unsubsidized ACA-compliant individual and small group market enrollees. They only shaved a little bit off of the proposed rates from late June, but every bit helps:

DOI Completes Review of Individual and Small-Group Health Insurance Rate Filings

The Kentucky Department of Insurance (DOI) announced today that it has completed its review of the individual and small-group insurance rates filed in the Kentucky market.  The rates will be used to calculate insurance premiums for the 2020 benefit year. 

I noted last month that Rhode Island was the latest state to put in for an ACA Section 1332 reinsurance program waiver:

Governor Raimondo’s proposed FY 2020 budget called for the creation of the Health Insurance Market Integrity Fund, which would make available reinsurance payments to health plans to reduce the burden of high cost claims on individual market premiums. According to insurer filings, the enactment of the Health Insurance Market Integrity Fund would reduce the individual market premium requests from 6.6% to -0.4% for BCBSRI and from 5.4% to 1.7% for NHPRI. These insurers’ pricing assumptions are subject to review and verification by OHIC. Table 1 shows the requested individual market rate increases with and without reinsurance.

Back in June I noted that Maine's Bureau of Professional & Financial Regulation released their preliminary 2020 rate filings for the Individual and Small Group markets. At the time, the three carriers on their Indy market were requesting average rate increases of around 4.7% next year.

In July I reported that the carriers themselves sliced their unsubsidized 2020 rates down of their own volition, to a 1.6% decrease on average.

Last week, after a public comment meeting, it looks like the Maine Insurance Dept. went ahead and approved the lower, revised rates for all three individual market carriers.

Last month I posted the average requested unsubsidized premium rate changes for the 2020 Individual Market in Ohio. At the time, the state was looking at a weighted average reduction of 7.0% from 2019 rates.

Since then, the Ohio Dept. of Insurance has reviewed and approved the rates for 2020, and while they don't provide much detail on individual carriers, overall it looks like they reduced rates slightly more (average reduction of 7.7%). The wording below is almost identical to what it was last month, except for the highlighted text:

Last month I reported on Tennessee's preliminary 2020 premium rate filings. At the time, the weighted average rate change for ACA Individual Market policies was a 1.1% reduction over this year.

Today, the Tennessee Insurance Dept. officially approved the rate changes exactly as is, without making any changes one way or the other:

TDCI Approves Carriers’ 2020 Rates on the Federally Facilitated Marketplace
More Choices, Rate Decrease Highlight Rating Filing Season

The Tennessee Department of Commerce and Insurance (TDCI) announces the approval of insurance rates requested by the five carriers offering coverage on the Federally Facilitated Marketplace (FFM) in 2020.

Back in mid-June, the DC Health Benefit Exchange Authority posted the preliminary, requested average unsubsidized 2020 premium changes for the Individual and Small Group markets:

Overall individual rates increased an average of 9.0 percent and small group rates increased an average of 10.5 percent. In the individual market, CareFirst proposed an average increase of 7.7 percent for HMO plans, and 15.6 percent for PPO plans. Kaiser proposed an average increase of 5.0 percent. For small group plans, CareFirst filed average rate increases of 13.5 percent for HMO plans and 18.5 percent for the PPO plans. Kaiser small group rates proposed an average increase of 3.0 percent. Aetna filed for an average increase of 16.1 percent for HMO plans and 5.0 percent for PPO plans. Finally, United proposed an average increase of 13.0 percent and 7.4 percent for its two HMOs and 11.2 percent for its PPO plans.

This is what it looked like at the time:

A few weeks ago I posted the preliminary 2020 ACA-compliant premium changes for Florida's Individual and Small Group markets. At the time, the requested rate hikes were only available for about 4 of the 10 carriers participating in the Individual Market, and just 10 of the 14 carriers on FL's Small Group market. However, the Florida Office of Insurance Regulation did provide the weighted average request: A 1.2% increase for the Indy Market and 6.4% for Small Group plans.

Today, FLOIR has released the approved rates for each, including the actual average changes for each carrier...and once again, they've whittled the rate changes down further yet on Indy plans (although they actually bumped them up a point on the Small Group market). From the press release:

OIR Announces 2020 PPACA Individual Market Health Insurance Plan Rates

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

(OK, no, this does not appear to be a "Yelp!"-like system where enrollees can directly influence the star ratings...I just posted the logo for the hell of it)

I didn't catch this when the press release went out a few days ago, but this could be significant...or it could be a big batch of nothing:

CMS is Bringing Health Plan Quality Ratings to All Exchanges for the First Time
Consumers will have improved access to health plan quality information for the 2020 Open Enrollment Period

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%).

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