2025 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 had enrolled in ACA-compliant individual market policies as of early this year;
  • 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 16 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 in those states the average premium rate changes listed (shown in grey) are unweighted averages, not weighted.

This can make a big difference.

  • 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.

In some of these states I've been able to acquire the actual effectuated enrollment for some carriers on the individual market but not all of them. In those states, combined with an educated guess as to the total market size, I've been able to run partially-weighted averages:

  • Let's suppose there are 4 carriers offering individual market policies in a state, but I only have the actual enrollment for the first two (30,000 and 120,000 respectively).
  • Let's say the average rate changes for each carrier are +12%, +4%, +1% and -3%
  • An unweighted average would be +3.5%, completely ignore the enrollment numbers.
  • Let's further say that according to the official CMS report, that state had 170,000 people enrolled in on-exchange policies as of February.
  • If I assume 85% of their enrollees did so on exchange, that would put the total market at 200,000 people. It would also mean the other 2 carriers with unknown enrollment numbers had 50,000 between them. I'd then assume 25,000 apiece in order to run a semi-weighted average.
  • This would give a semi-weighted average of +3.95%, rounded up to +4.0%.

The problem with doing this is that I'm making two big assumptions: First, that on-exchange enrollees make up 85% of the total; second, that the "missing" enrollees are evenly spread across the other two carriers. However, it's still more accurate than just running a completely unweighted average.

As of September 24th, I have the preliminary (requested) 2025 statewide average rate changes for all 50 states plus the District of Columbia, giving a national average requested rate increase of 6.13%. Again, it's important to remember that this includes 16 states where I've had to use either unweighted or partially-weighted averages.

I've also been able to run the numbers for the final, approved rate changes in 17 states (all of which happen to be fully weighted). Across those 17 states only, the final average premium increase for unsubsidized individual market enrollees is 7.3%. This will shift higher or lower as each of the remaining states has their 2025 rate changes finalized.

Sorry about the headline, but it's kind of difficult to focus on stuff which seems pretty mundane at the moment.

Still, it is part of my job to analyze the annual weighted average premium rate changes for ACA individual & small group policies to the best of my ability, so I'm doing that.

The final/approved rates for 2025 mostly come from the federal rate review database, although in some states they come directly from their insurance department website or the SERFF database.

Oddly, the federal rate review database still only has partial data for Oklahoma and Tennessee, and none at all for Wyoming, even though we're nearly a week open enrollment, so I can't plug those in yet. Huh.

Originally posted 9/09/24

Ah, at last, another state which includes both the average requested rate changes for 2024 as well as the number of enrollees each carrier has for both the individual and small group markets in clear, transparent language!

Generally, according to NC Insurance laws, health insurance rates must not be excessive, inadequate, or unfairly discriminatory, and must exhibit a reasonable relationship to the benefits provided in the policy.

Overall, individual market carriers in North Carolina are requesting 7% rate increases in 2025 for unsubsidized policies, while small group market carriers are asking for a 6.5% bump. It's worth noting that one of the three (!) UnitedHealthcare divisions is pulling out of the NC small group market next year for whatever reason.

Originally posted 9/12/24

Unfortunately, South Carolina is another state where they don't make unredacted rate filings available, either on the state insurance dept website, the federal Rate Review website or the SERFF database.

As a result, I'm limited to unweighted averages for both the individual and small group markets:

  • Individual Market: FLAT
  • Small Group Market: +6.7%

I'm estimating the total individual market at perhaps 700,000 people, based on an assumption that 80% are enrolled in on-exchange plans.

It's worth noting that Cigna Healthcare is dropping out of the South Carolina individual market next year, while Aetna is pulling out of the small group market (see below).

via the Colorado Dept. of Regulatory Agencies:

Polis-Primavera Administration’s Landmark Reinsurance Effort Will Save Coloradans $493 Million on Healthcare Premiums in 2025, Putting Money Back in the Pockets of Hardworking Coloradans

Even more savings can be found by shopping and switching to a Colorado Option plan during open enrollment

DENVER - Today Governor Polis, Lt. Governor Primavera, and the Colorado Division of Insurance (DOI), part of the Department of Regulatory Agencies (DORA), announced that Reinsurance will save Coloradans almost $493 million on approved plans and premiums for 2025, building on the millions in savings available to Coloradans through Colorado Option plans. The figures below on the final, approved health insurance plans and premiums for 2025, highlight the impact of these efforts to save people money on health insurance. 

Originally posted 9/09/24

The bad news is that I was only able to acquire effectuated enrollment for 3 of New Mexico's 4 individual market carriers participating in 2025 (a fifth carrier, Western Sky, is dropping out of the market entirely).

The good news is that I'm able to roughly estimate the enrollment of the remaining carrier (BCBS NM) if I look at on-exchange effectuated enrollment as of February and assume that another 10% or so is off-exchange. That gives me an estimated weighted average increase of 10.6%.

Even if that estimate is wrong, it doesn't make much difference since the unweighted average is around 10.1% anyway.

As for the small group market, I only have an unweighted average there of 8.6%.

Arizona

Originally posted 8/13/24

The good news is that the federal Rate Review database has now posted the preliminary avg. 2025 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 2025 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%.

Back in late August, Covered California issued a formal press release stating that average 2025 rate increases for individual market policies would average 7.9% statewide.

However, that was actually only for the preliminary rate filings. In addition, at the time I only had access to California's on-exchange individual market enrollment data, so I had to guess at the off-exchange numbers.

The small group market was more frustrating: I only had enrollment data for about 1/3 of the carriers; the rest had redacted their enrollment information. This meant I couldn't even guess at a weighted average rate change.

Fortunately, my friend & colleague Louise Norris reminded me that California has, in addition to their official Insurance Department, a second insurance regulatory body, the Dept. of Managed Healthcare, which has its own database of individual, small group and large group market rate filings.

Originally posted 9/12/24

via the Pennsylvania Insurance Dept:

PID is working with insurers to review proposed changes to ensure rates are adequate and fair.

 Harrisburg, PA – The Pennsylvania Insurance Department (PID) today announced that 2025 rate changes requested by insurance companies currently operating in Pennsylvania's individual and small group markets are now available online. This initiative upholds the Shapiro Administration's commitment to providing consumers with the information they need when shopping for health insurance. 

Rate filings for 2025 health insurance plans were submitted to PID on May 15, 2024. Ever since, PID has been working with insurers to review these insurance companies' proposed rate changes, as rates vary by plan and region and are subject to change by the Department to ensure rates are adequate and fair. Final approved rates will be made public in the fall. 

Originally posted on 9/05/24

This press release is from August 1st (sorry, still playing catchup):

Nevadans Get a Preview of 2025 Proposed Health Insurance Rate Changes for Upcoming Open Enrollment

 Starting today, Nevada consumers who shop for their health insurance on the individual health insurance market can view and provide comments on proposed rate changes for Plan Year 2025.

The Nevada Division of Insurance (Division) has received and made public on its website the 2025 proposed rate changes from health insurers intending to sell plans on and off the Silver State Health Insurance Exchange (the "Exchange"). The Exchange is the state agency that assists eligible Nevada residents to purchase affordable health and dental plans.

Originally posted 8/14/24

via the Idaho Dept. of Insurance:

Each year, the Idaho Department of Insurance posts rate changes of individual and small group health insurance products so consumers can review and provide comments on the proposed increases.  Insurance companies submit proposed rates for the upcoming calendar year to the Department, along with descriptions and justifications for why the rates are reasonable and not excessive.  The Department of Insurance is seeking public input for rate changes of individual and small group health insurance products to improve insurer accountability and transparency.  By following the links below, the public can access a summary of the increase amounts and the carrier justifications for the rates.  Please submit any comments to the Department for consideration.

Preliminary Rates - 2025

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