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.

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 (14) and small group (16) markets. Their small group market is losing 2 carriers next year (All Savers and Common Ground Health Co-op), but it's still pretty robust.

The bad news is that it's once again extremely difficult to acquire Wisconsin's actual rate filings prior to the actual Open Enrollment Period launching, meaning I can only run unweighted average requested rate increases/decreases for the most part, although I've made a crude attempt at a partially-weighted average for the individual market.

With that in mind, individual market carriers are requesting unweighted increases of around 9.1%, while small group carriers are seeking hikes of around 7.4% overall.

Well whaddya know? After years of their actuarial memos being redacted and/or filing summaries missing critical info, this year I'm suddenly able to access all the data I need!

West Virginia carriers are asking for average rate hikes of 7% on the individual market and 8.2% for small group plans.

The 7% hike is pretty close to the average nationally on a percentage basis...but since West Virginia also already has by far the highest average unsubsidized premiums in the nation, that's ugly news, especially if the enhanced ACA subsidies provided by the Inflation Reduction Act are allowed to expire starting in 2026...

Utah's preliminary 2025 individual and small group market rate filings are listed below. They launched a handy new website specifically dedicated to insurance filings, which is nice to see.

Unless there's a change in the final/approved rates, unsubsidized individual market plan premiums are increasing by around 10.4% in 2025, while small group plans will go up 8.9% on average.

It's worth noting that Cigna Health & LIfe is pulling out of Utah's individual market next year, while Angle Insurance Co. is dropping out of the small group market.

It's also worth noting that virtually all of Utah's individual market enrollment appears to be on exchange this year...over 95% of it! It's slightly lower than that since I don't know how many enrollees Cigna has at the moment, but they only reported around 3,000 effectuated enrollees as of a year earlier, so unless they had massive growth this year (which could have happened, I suppose), it would only knock the on exchange percentage down a point or two.

Cigna notwithstanding, this means that in Utah:

  • 95.3% of all indy market enrollees are on exchange
  • 91.4% of all indy market enrollees are subsidized

As always, the Texas individual and small group markets are pretty messy. For starters, they have up to 20 individual market carriers depending on the year, along with over a dozen small group market carriers some years (this year they're at 17 and 8 respectively).

On top of that, as is also the case in some other states, some of the names of the insurance carriers can be confusing as hell. There's the "Insurance company of Scott & White" which seems to have changed its name to "Baylor Scott & White Insurance Co.," which isn't to be confused with "Scott & White Health Plans" and so on.

I was only able to acquire hard enrollment data for five of the carriers on the individual market this year, and one of those doesn't really count since they're brand new and don't have any (Wellpoint Insurance Co.). For another 11 of them the rate filings include the number of policyholders but not the actual number of covered lives; for those I'm using an average 1.4x multiplier, based on the actual multiplier found in the carriers I have both numbers available for.

Tennessee's preliminary 2025 individual & small group market health insurance rate filings are now available. Unfortunately, I can't find any unredacted filing forms for any of them (and in fact most of the rate filings aren't showing up in the SERFF database at all).

For the most part there's not much to see at first glance: Requested rate changes range from a 1.3% drop to a 3.9% increase on the individual market and from a 9.7% to 11.2% increase for small group plans. The unweighted averages are +1.4% and +10.6% respectively.

However, it also looks like several carriers are dropping out of each market in Tennessee: Alliant and US Health & Life (Ascension) don't show up on the federal Rate Review database for the individual market, while Aetna and CIGNA are missing for small group listings.

Assuming the exchange-based market makes up roughly 85% of total individual market enrollment in Tennessee, the total indy market should be around 628,000 people.

Pretty straightforward in the Mount Rushmore state. Three carriers on the individual market; around 56.4K enrollees total. The weighted average rate change across all three is +2.3% if approved as is.

Note that I've added a new feature to my rate change spreadsheet this year: I've started including the on exchange effectuated enrollment as well as the subsidized on exchange enrollment as of February for every state. This will allow me to calculate the percent of the total individual market which is receiving ACA subsidies...at least in states where I'm able to figure out what total off-exchange enrollment is (typically only around half of them).

In South Dakota, for instance:

  • 95.7% of on exchange enrollees are subsidized (49,250 / 51,416)
  • 87.2% of the total market is subsidized (49,250 / 56,457)
  • On exchange enrollment makes up around 91% of the total individual market

For the small group market, there are five carriers this year; Medica Insurance Co. appears to be pulling out of the state. The weighted requested average rate change is a 2.8% increase.

I got so far behind on my annual rate filing project that some of the states have started issuing their APPROVED changes before I got around to analyzing the REQUESTED rate changes. Ah, well...

Via the Rhode Island Insurance Department:

2025 Commercial Health Insurance Rates Have Been Approved with Modifications

CRANSTON, R.I. (September 3, 2024)

The Ohio Insurance Department does this weird thing where they list all of the carriers offering policies on the individual market and list the weighted average year over year premium change...but they don't list the actual rate increases for each carrier. Fortunately, federal Rate Review site includes the rate changes, and the SERFF database for Ohio includes the actual enrollment numbers for all of the individual market carriers.

As a result, I've been able to put together a weighted average requested rate increase for the individual market, which comes in at +3.9%.

For the small group market, I have to go with an unweighted average of +12.0%. It's also worth noting that it looks like one of Aetna's divisions is pulling out of the OH small group market, as are two fof the 4 (!) UnitedHealthcare divisions and possibly AultCare, although I'm not sure about that one.

North Dakota only has 3 carriers participating in their individual health insurance market and four in their small group market, since it appears that Health Partners will be pulling out of the latter next year.

For the indy market, the weighted average premium increase being requested is a painful 16.7%, although this may be off slightly due to Medica's enrollment number being a rough estimate (last year's total ND market was only 45,000 people; I'm assuming Medica only has around 2,000 enrollees this year).

For the small group market, I only have the unweighted average rate hikes, which come in at 10.8%.

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.

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