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.

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.

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%.

New Jersey individual & small group market carriers are asking for unweighted average rate increases of 7.3% and 4.5% respectively for 2025. However, the unweighted averages don't tell the whole story--the carriers are asking for rate hikes ranging from as low as 3.8% to as high as 16.2% on the individual market, and from as low as an 18.8% reduction to a 12.3% increase for small group plans.

As is the case with far too many states these days, most of the rate filing memorandums are heavily redacted in New Jersey, making it nearly impossible to get ahold of the actual enrollment numbers, which means I have no way of running a weighted average on either market.

I should note that the 433,000 estimate for New Jersey's total individual market is based on the assumption that 90% of it is via the ACA exchange, with only 10% being enrolled off-exchange.

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.

Nebraska doesn't even bother listing indy/small group plan rate filings on their own insurance department website...the link goes directly to the federal Rate Review database. The problem with this is that very few filings here are unredacted, which means it's difficult to acquire the policy enrollees for many carriers needed to run a weighted average.

Nebraska has 4 carriers on the individual market for 2025: BCBS, Medica, NE Total Care and Oscar Health. The unweighted average rate increase being requested is around 4.0%.

For the 4 Small Group market carriers, I do have enrollment data for two of them, but without knowing the other two this isn't terribly useful. The unweighted average rate change being requested there is a 9.3% increase.

Montana used to be very good about providing rate filings in a clear, upfront, transparent manner.

That is no longer the case. Their insurance department website hasn't updated the rate filings page for two years.

The good news is that this year at least, the SERFF database has both the average rate changes as well as the 2024 effectuated enrollment for all carriers on both the individual and small group markets. There's one curiousity, however: For the small group market, UnitedHealthcare shows up in the SERFF database but doesn't appear on the federal Rate Review website.

This doesn't really move the needle much either way, however, since UHC only reports having 250 enrollees anyway.

In any event, individual market carriers are requesting average 8.3% rate increases, while small group carriers are asking for similar 8.6% hikes.

The Missouri Insurance Dept. has posted their preliminary 2025 single risk pool filings for the individual and small group markets.

Not a whole lot stands out to me other than SSM Health Insurance apparently dropping out of the states indy market and a new carrier, Bankers Reserve Life Insurance, newly joining it.

At the same time, the Missouri small group market appears to be losing two carriers (or three depending on your POV): Aetna Health, Aetna Life and Cigna Health & Life are all missing from the 2025 filing summaries as well as the federal Rate Review database.

In any event, the MO individual market is looking at average premium reductions of 1.7% if approved as is, while small group plans are likely to increase by about 7.9% overall.

As always, these are subject to state regulatory review and approval.

Unfortunately, Mississippi is another state which provides zero useful rate filing data for my purposes (preliminary or final) prior to the Open Enrollment Period launching. The only data I have is from the federal Rate Review website, and even the filing forms there are heavily redacted, so all I can put together are unweighted averages for the 2025 calendar year.

It's worth noting that Vantage Health Plan appears to be dropping out of the individual market, while All Savers appears to be dropping out of the states small group market (at least, neither one shows up on the Rate Review site or in a SERFF search, anyway).

UPDATE: Thanks to Paul in the comments for noting that Vantage simply changed their name to Primewell last year.

With that in mind, unsubsidized individual market enrollees are looking for unweighted average increases of around 1.8%, while small group carriers are hoping to increase rates by around 9.8% (again, unweighted).

Originally posted 8/09/23; updated 11/07/23

Louisiana's rate filing database is frustrating, because it's both highly-detailed and confusing at the same time.

They break out the filings not between Individual and small group markets or on- vs. off-exchange policies, but between rate increases over and under 10%. Normally that would be fine, but they also have multiple listings within each market for several carrier.

Not that any of that matters this year, as they don't appear to have posted any of the ACA-compliant individual market filings there anyway. I had to rely entirely on the federal Rate Review site, and the filings there still don't include enrollment data for most carriers, so the averages below are all unweighted only:

  • Individual Market: Around 3.0% lower (in fact, 4 of the 5 carriers on the market next year are dropping average premiums at least slightly)
  • Small Group Market: 9.6% higher

It's worth noting, however that Louisiana Healthcare Connections appears to be dropping out of the individual market entirely.

Kansas

Kansas is another state where the annual rate filings are redacted for many of the carriers; as a result, I can only run a semi-weighted average, and even that is dependent on my estimate of the total individual market size being accurate (my general rule of thumb as long as the enhanced subsidies of the IRA are in place is that about 90% of most states individual market enrollment is on-exchange unless I have data proving otherwise).

With that in mind, the carriers on the Kansas individual market are asking for rate hikes ranging from 2.1% - 24.4%, with an estimated semi-weighted average of 8.9%.

For the small group market, I can't even run a semi-weighted average since I have no idea what the KS small group market size is overall, but the unweighted average rate hikes being requested is 14.9%.

It's also worth noting that unless I'm missing something, US Health & Life Insurance seems to be pulling out of the Kansas individual market, while both Aetna and Cigna seem to be missing from the small group market.

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