OK, after several weeks of this site turning into AnnualRateFilingsDotCom, I'm finally catching up on some other important ACA/healthcare-related developments which are happening.
I've finally completed my Annual Individual & Small Group Market Rate Filing project for preliminary 2024 rate filings, having analyzed & crunched the numbers for the individual and small group markets across all 50 states + DC, so it's time to step back and see where things stand nationally.
It's important to remember that these are preliminary filings only--many of the carriers will have their final 2024 rate changes reduced, although in many cases they tend to be approved as is.
It's also important to note that I only have weighted average rate changes for 30 states (+DC). For the other 20 states, I've only been able to generate unweighted average rate changes--that is, I have to assume every carrier in that state has the same number of ACA enrollees since their rate filing forms are either unavailable or heavily redacted, making it impossible for me to know how many people are enrolled in their policies.
The main reason for this was the implementation of a so-called "reinsurance" program which was originally passed by the (then Democratically-controlled) state legislature:
The most significant thing to impact Virginia carriers 2023 filings was the state's Section 1332 Reinsurance Waiver. I wrote about this way back in 2018 when the state was originally considering applying for one, but it didn't actually go into effect until January 2023:
Shapiro Administration Announces Public Comment Period On Proposed 2024 Health Insurance Rate Increases
Harrisburg, PA – Pennsylvania Insurance Commissioner Michael Humphreys today welcomed public comment on the requested rate changes insurance companies currently operating in Pennsylvania's individual and small group market filed for 2024. The comment period on the proposed rate increases will close on September 8.
"The Shapiro Administration is committed to raising awareness about the importance of health insurance and providing increased access to affordable, comprehensive health coverage," said Humphreys. "We strongly encourage individual market consumers to shop for coverage on Pennie® where they may qualify for financial assistance that, as we consistently hear from Pennsylvanians, makes coverage more affordable than they thought might be possible."
Oklahoma is another state where I have no access to the actual enrollment data--all I have to go by are the average requested rate changes for each carrier on the individual and small group markets. As a result, the averages for each market are unweighted.
For individual market plans, that unweighted average is just 2.2%, though the carriers range from as low as a 3.5% drop to as high as a 6.1% increase. It's also worth noting that Friday Health Plans are kaput.
Similarly, for the small group market, average requested rate hikes range from as little as 0.8% for CommunityCare to as much as a 9.3% for Aetna. The unweighted average is 4.9%.
Not much to report about the 2024 individual and small group market rate filings. I could only find current enrollment numbers for two of the three indy market carriers and for three of the five small group market carriers. However, based on last year's total enrollment, I'm estimating ND's total indy market at being roughly 50,000 people, which means I was able to make an educated guess at how many are enrolled in Sanford Health Plan policies.
Based on this, I have a (mostly) weighted requested average rate increase of 4.4% for individual market plans and an unweighted average of 6.5% for small group market plans.
New Jersey individual & small group market carriers are asking for unweighted average rate increases of 6.7% and 13.0% respectively for 2024. 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 13.8% on the individual market, and from as low as 2.3% to a stunning 25.9% 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.
While nearly 16.4 million Americans selected Qualified Health Plans (QHPs) via the federal and state ACA exchanges/marketplaces during the official 2023 Open Enrollment Period (along with an additional 1.2 million signing up for a Basic Health Plan (BHP) program in New York & Minnesota, which CMS continues to inexplicably treat as an afterthought in such reports), not all of them actually pay their first monthly premium (for January) for various reasons:
The good news about New Hampshire's health insurance market is that they're the only state without its own ACA exchange which produces publicly-accessible monthly reports on individual on-exchange market enrollment. The bad news is that they don't seem to publish the actual rate filings in an easy-to-read format, which means I'm left with the federal rate review website, which sometimes posts average rate requests which don't match up with the actual filings...but it's gonna have to do here.
With these two data sources in hand, New Hampshire's individual market carriers are asking for a weighted average increase of 3.1%. It's important to note that Anthem Health Plans and Matthew Thornton Health Plan are listed as separate carriers on the federal Rate Review website (with separate average rate requests), but on the state's monthly report, they're merged into a single listing.
Nevada used to be a state where the annual individual & small group rate filings were fairly transparent. They have a pretty easy-to-use searchable filing database which clearly lists the carriers, market, maximum & minimum rate changes and even includes the SERFF Tracking numbers for every filing.
Unfortunately, this year at least, most of that proves useless for my purposes. The average rate changes are posted, but the enrollment data is still hidden from public view--entering the SERFF Tracking Numbers still brings up nothing in the SERFF database, and the actuarial memos posted at RateReview.HealthCare.Gov are mostly redacted. As a result, I'm only able to enter enrollment data for one of the nine carriers on the Nevada individual market, and none on the small group market.
Interestingly, the one I have enrollment data for (Aetna Health of Utah) also has a curious discrepancy: The filing itself lists the average requested rate increase as being 6.97%, but on the RR.HC.gov site it only shows up as 1.36%. The other eight carriers all match up (or are within a tenth of a percentage point, anyway).
