2022 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.

Unfortunately, there are about a dozen states where due to the carriers and/or the state insurance departments heavily redacting the rate filing documentation, I've been unable to fill in the actual number of people enrolled by some or all of the insurance carriers within that state's individual market. This means that the average premium rate changes listed (shown in grey) are unweighted averages, not weighted.

This can make a big difference in some cases: Let's say you have 2 carriers in a state, one raising rates by 10% and the other raising them by 1%. The unweighted average increase would be 5.5%. However, what if it turns out that the first carrier has 90% of the market share while the second only has 10%? That would mean a weighted average increase 9.1%. The unweighted average is the best I can do for these states without knowing the market share breakout, however.

As of this writing, I've plugged in the preliminary (requested) 2022 statewide average rate changes for all 50 states plus the District of Columbia, giving a national average increase of 3.9% overall. I've also entered the final (approved) averages for 19 states so far. For those states, the national weighted average increase is a bit higher, 4.8%. This will likely drop as more final averages are entered in the coming weeks hover; the odds are high that once every state is filled in, the final average increase will be slightly lower than the preliminary average.

UPDATE 10/19/21: I've filled in the final/approved averages for Oregon, Indiana, Delaware, Connecticut and Idaho, which collectively whittle the final national average down from 4.8% to...4.6%.

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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:

Pennsylvania

I can't overstate how much I wish every state was as good as Pennsylvania is at not only making their annual rate filings publicly available on the state insurance dept. website, but doing so in such a clear, simple format, while also including a consistent summary page for every carrier!

As a result of this attention to transparency and detail, I was able to put together my Pennsylvania analysis pretty quickly even though they hae a huge number of carriers on both their individual and small group markets.

Aside from Cigna joining the PA indy market, not too many surprises in the Keystone State this year...approved average indy market premiums are staying nearly flat overall (+0.2%), while small group plans will cost around 4.8% more than last year on average.

Texas

Texas' annual health insurance rate filings are kind of a mixed bag in terms of transparecy. Hardly any of the carriers have Uniform Rate Review Template (URRT) forms or Rate Filing Justification Form Part II available (these are the documents which generally include the actual number of people enrolled in the policies for each market for that insurance carrier), and the Actuarial Memorandum (Part III) is heavily redacted for most of them, making it very difficult to lock in the actual enrollment numbers.

On the other hand, a few of them do offer one or both of the former documents, and in a few cases I was able to get the policyholder figures via the SERFF database. I'm operating on the assumption that each individual market policy has roughly 1.5 covered lives apiece on average.

Unfortunately, without having even that estimate available for half the carriers offering policies in Texas, I can't run a weighted average increase (it comes to +4.9% using what I have available), so I'm left (once again) with an unweighted average of around +1.5% on the individual market and +6.1% for small group policies.

North Dakota

There are 9 states where I've been unable to track down the actual enrollment data for individual market carriers. North Dakota is among them.

The unweighted average rate increase for 2022 is 6.0% for the ND individual market and 5.3% for the small group market, which consists of the same three carriers (UnitedHealthcare was a fourth participant in ND's small group market in 2021, but they aren't listed in the federal Rate Review database as of this writing, so I'm assuming they're pulling out).

Virginia

Virginia has an extremely robust, competitive individual & small group insurance market...and in 2022 it's getting even more competitive, with three new carriers joining the individual market: Aetna, Bright and Innovation Health Plan.

Beyond that, I don't see any shocking or dramatic developments for 2022; average unsubsidized individual market premiums are dropping by 2.9% statewide, while average small group premiums are increasing by 3.6% overall.

West Virginia

Good grief.

West Virginia has the second-smallest ACA individual market enrollment total (Alaska has the smallest), while also being one of the only states left which has (until 2022) refused to use #SilverLoading in their premium pricing strategy to provide some relief to moderate-income indy market enrollees.

As a result of this and other factors, they now have the highest unsubsidized individual market policy premiums in the country (19% higher than the prior record-holder, Wyoming, which averaged $870/month in 2021), at $1,038/month per enrollee.

In 2022, this is gonna be even more jaw-dropping, as the approved rate increases for WV's carriers will average 12.8%, bringing the average premium up to a whopping $1,171/month per person.

The good news is that starting in 2022, as noted by Dave Anderson, it looks like West Virginia will finally join nearly every other state in Silver Loading as well, which will help a bit:

Wisconsin

I'm pretty sure Wisconsin has the most competitive ACA markets in the country, at least in terms of the sheer number of insurance carriers offering policies on both the individual and small group markets. A total of 37 are present at the moment, although 5 of the small group carriers don't appear on the federal Rate Review database as of yet.

Unfortunately, this is yet another state where the enrollment data has basically been buried, so I can only run unweighted average rate changes.

With that in mind, the individual market rates look to be nearly flat (dropping by 0.8% on average), while small group plans are going up 4.4%.

Vermont

Vermont's 2022 rate filings are pretty straightforward: They only have two carriers in the state offering either individual or small group plans to begin with, and the insurance department clearly states not only the requested and approved rate changes, but the exact number of enrollees each carrier has.

There's one major change this year, however: After many years of having their individual & small group risk pools merged, Vermont has decided to unmerge the two (I believe Massachusetts is the only other state which has a combined indy/small group risk pool). The press releases for rate filings in each explains the rationale:

GREEN MOUNTAIN CARE BOARD REDUCES RATE REQUESTS FOR INDIVIDUAL AND FAMILY PLANS FOR 2022

Utah

Utah has an elaborate, color-coded public database which lets you search for health insurance rate filings for not just the current and upcoming year, but also for years dating back nearly a decade. It can be a bit confusing (for instance, the "Latest Rate Changes" section on the main page is currently blank even though both the individual and small group plans for 2022 were all recently approved), but it's still a lot better than most states offer.

Between this database and Utah's SERFF listings, I've been able to put together the full requested and approved filings for every carrier in both markets, along with the enrollment numbers for each, allowing for weighted average increases.

Individual market enrollees are looking at roughly a 1% average unsubsidized rate increase, while small group plans are goin gup about 4.5% overall. From what I can tell, WMI Mutual is dropping off the small group market, but they don't have anyone enrolled in their policies right now anyway.

Illinois

Unfortuantely, Illinois is another state which doesn't make it easy to analyze annual health insurance premium rate filings. There's no details on their insurance department website, their SERFF listings don't seem to include the actuarial memos or URRT forms, and even the federal Rate Review listings only include the average requested rate changes; the actuarial memos there are mostly heavily redacted.

The unweighted average rate changes requested for 2022 come in at +5.1% for the individual market and +3.5% for small group plans. It's worth noting that neither of the UnitedHealthcare listings from 2021 (on the small group market) show up in the federal database, which either means they're pulling out of the Illinois market entirely or they just haven't been added to the listings yet. Given that it's mid-October, the former seems more likely.

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