New Hampshire: Approved (?) unsubsidized rate hikes: ~52%; 5.2 pts due to CSRs (?)

As noted earlier today, I've now managed to plug 48 states (plus DC) into my 2018 Rate Hike Project spreadsheet. This leaves just two states missing: New Hampshire and Texas. I'm still waiting to clarify some things for each, so this analysis could still change, but I really want to wrap this up, so here's what I have for New Hampshire right now:

When I first ran the numbers for New Hampshire's requested 2018 rate increases, it seemed pretty straightforward: 3 carriers on the individual market. 2 listed rate changes assuming CSRs would be paid; one assumed they wouldn't. This gave the following:

Cut 'n dry, right? Guess again: An August press release from the NH Dept. of Insurance stated:

The information published today by the federal government shows that some of the state’s insurers have submitted benefit plans for the individual market with substantial increases. The New Hampshire Insurance Department looks at premiums each year from a market-wide perspective, comparing the median premium for a silver-level plan covering a 40-year-old non-tobacco-user. For 2017, the median premium at this level was $335; the median premium at this level for 2018 would be $479, based on the carriers’ initially proposed rates. If these rates are ultimately approved, this would represent a 43% increase between next year’s and this year’s median premium in the individual market.

I had to take that with a grain of salt, however, since they referred to the median increase, not the average.

Then, a few days ago, the New Hampshire DOI issued another press release, stating:

“It’s important to note that not everyone who buys an individual health insurance plan will be affected: The roughly 29,000 New Hampshire residents who receive federal subsidies through likely won’t experience much change in what they actually pay in monthly premiums,” said New Hampshire Insurance Commissioner Roger Sevigny. “However, the 24,000 residents who don’t qualify for a federal subsidy or who buy a plan outside will see an average increase of 52 percent. We realize what a difficult situation those people will face and want to make sure they have all the information and resources available in order to help them make decisions.”

And sure enough, when I plugged in Avalere Health's analysis data (which breaks out the 2018/2017 numbers by metal level) and combined that with CMS's Public Use Files for 2017, I got the following:

49.2% with the full CSR load added...a bit lower than 52% but pretty close when you consider that the off-exchange market isn't included.

OK, fine; 52% it is.

That still leaves figuring out just how much of that hike is due to the CSR load itself. The Kaiser Family Foundation projected only around 10 points would be added to Silver plans, which would translate into just 5.6 points across all metal levels, which would mean something like this:

I've put in a request with the NH DOI about this; not only does 5.6 points sound awfully low (that's only 11% of the total rate increase), but judging by the % Change column, it sure looks like New Hampshire is "Broad Loading" instead of "Silver Loading" as well, so I'm not sure what to make of it.

Stay tuned...