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.

Alaska is a sparsely populated state with only two carriers on their individual market and four on their small group market. Alaska's insurance department website is useless when it comes to getting rate filings or enrollment data; I had to use the federal Rate Review site to even get the requested rate changes.

Fortunately, both carriers (Premera Blue Cross and Moda Health Plan) include summaries which list their current enrollment data. Unfortunately, the average rate increase being requested by the carriers for 2025 is up another 17%. While nearly all ACA exchange enrollees receive financial subsidies, this is still pretty steep for the few who aren't.

From Premera's summary:

Originally posted 8/05/24; updated 9/19/24

The good news is that RateReview.HealthCare.Gov has posted the preliminary 2025 rate filing summaries for every state, making it much easier to pin down which carriers are actually participating in the individual & small group markets next year, as well as what the carriers average requested rate changes are in states which don't publish that data publicly (or which make it difficult to track down if they do).

The bad news is that in many of those states, acquiring the actual enrollment data is even more difficult, as their rate filings tend to be heavily redacted.

Michigan

The Michigan Dept. of Financial Services hasn't issued any press release yet, but nearly all 2025 preliminary rate filings for the MI individual and small group markets are available via the SERFF database.

The most noteworthy item in Michigan's individual market is that there's a new entry: HAP CareSource. I'm assuming this is some sort of joint insurer effort by CareSource and Health Alliance Plan (which has only offered off-exchange ACA plans for several years now) but am not certain about that.

In terms of actual rate hikes, most of them are in the mid single digits, but Priority Health, which holds exactly 1/3 of the market share (equal to Blue Cross when you combine their PPO & HMO divisions), is seeking an eye-opening 18.9% average rate increase.

With Priority Health included in the mix, rate increases being requested by Michigan indy market carriers average 10.5% for 2025.

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