OE7

Back in mid-June, the DC Health Benefit Exchange Authority posted the preliminary, requested average unsubsidized 2020 premium changes for the Individual and Small Group markets:

Overall individual rates increased an average of 9.0 percent and small group rates increased an average of 10.5 percent. In the individual market, CareFirst proposed an average increase of 7.7 percent for HMO plans, and 15.6 percent for PPO plans. Kaiser proposed an average increase of 5.0 percent. For small group plans, CareFirst filed average rate increases of 13.5 percent for HMO plans and 18.5 percent for the PPO plans. Kaiser small group rates proposed an average increase of 3.0 percent. Aetna filed for an average increase of 16.1 percent for HMO plans and 5.0 percent for PPO plans. Finally, United proposed an average increase of 13.0 percent and 7.4 percent for its two HMOs and 11.2 percent for its PPO plans.

This is what it looked like at the time:

A few weeks ago I posted the preliminary 2020 ACA-compliant premium changes for Florida's Individual and Small Group markets. At the time, the requested rate hikes were only available for about 4 of the 10 carriers participating in the Individual Market, and just 10 of the 14 carriers on FL's Small Group market. However, the Florida Office of Insurance Regulation did provide the weighted average request: A 1.2% increase for the Indy Market and 6.4% for Small Group plans.

Today, FLOIR has released the approved rates for each, including the actual average changes for each carrier...and once again, they've whittled the rate changes down further yet on Indy plans (although they actually bumped them up a point on the Small Group market). From the press release:

OIR Announces 2020 PPACA Individual Market Health Insurance Plan Rates

Back in June, the New Mexico Insurance Dept. posted the preliminary 2020 rate change filings for the ACA individual and small group markets. At the time, the vcarriers were requesting the highest average premium increase in the country for next year: An increase of 13.0%.

The main source of this double-digit hike was New Mexico Health Connections, one of just a handful of original ACA Co-Op carriers to survive. They were requesting a whopping 30% average rate hike for 2020, and with over 1/3 of the market share, this was more than enough to drag the statewide average up. A second carrier, Presbyterian, only sells off-exchange but was requesting a 16.3% increase which also pushed the average up.

Well, today the approved rate filings have been released, and there's several eyebrow-raising developments.

First of all, there's this (first noted by Sabrina Corlette):

CHRISTUS HEALTH PLAN LOSES QUALIFIED HEALTH PLAN STATUS

(OK, no, this does not appear to be a "Yelp!"-like system where enrollees can directly influence the star ratings...I just posted the logo for the hell of it)

I didn't catch this when the press release went out a few days ago, but this could be significant...or it could be a big batch of nothing:

CMS is Bringing Health Plan Quality Ratings to All Exchanges for the First Time
Consumers will have improved access to health plan quality information for the 2020 Open Enrollment Period

I've finally analyzed and posted my 2020 premium rate filing analyses for all 50 states (+DC), so this seems like a good time to take a look at the big picture. The table below summarizes the preliminary filings for every state, with four exceptions where the approved (or at least mostly-approved, in the case of Oregon) average rate changes are listed. Nationally, it looks like insurance carriers are only requesting an average premium increase of about 0.6% for the ACA-compliant individual market in 2020. A few caveats:

Vermont is the fourth state to announce their approved 2020 ACA individual/small group market premium rate changes. VT (along with Massachusetts and DC) has (wisely, in my opinion) merged the risk pools for the two markets into one, meaning I have to plug the numbers in differently on my spreadsheet.

Back in mid-May, my initial analysis of the two carriers participating in both Vermont markets put the weighted average rate increase being requested at an even 13.0% statewide: Blue Cross Blue Shield of VT was requesting a 15.6% increase, while MVP Health Care asked for a 9.4% bump.

From the Green Mountain Care Board a few days ago:

GREEN MOUNTAIN CARE BOARD MODIFIES AND APPROVES RATE REQUESTS FOR 2020 VHC PLANS

Back on May 31st, I reported that New York's Dept. of Financial Services had released the preliminary, requested premium rate hikes for the 2020 ACA individual and small group markets. At the time, the weighted average increase requested state-wide was around 8.4% (although I got 8.3% when I plugged the hard enrollment numbers into a spreadsheet).

For the small grouip market, NY DFS reported an average requested increase of 12.0%, although again, I only got 11.3% when I plugged in the numbers.

Yesterday, however, NY DFS became the third state (after Oregon and Virginia) to publicly release their approved 2020 premium changes...and like OR & VA, they've shaved a few points off the average rates:

DFS ANNOUNCES 2020 PREMIUM RATES: LOWERS OVERALL REQUESTED RATES FOR INDIVIDUALS AND SMALL BUSINESSES TO PROTECT CONSUMERS AND FUEL A COMPETITIVE HEALTH INSURANCE MARKETPLACE

At long last, I've completed my analysis of the preliminary 2020 rate filings for ACA-compliant individual market policies across all 50 states (+DC)! in most cases I've also included the small group market, although with far less documentation for those.

Texas, understandably enough, has the third largest individual market in the country after California and Florida, at somewhere around 1.27 million enrollees (they had around 990,000 on-exchange enrollees; I'm pretty sure around 75% of the market is on-exchange these days).

There's ten carriers offering ACA policies on the individual market in Texas, and fifteen participating in the small group market. Unfortunately, most of the rate filings are redacted or missing data altogether (again), so I was only able to cobble together hard enrollment data for half the Indy market carriers, comprising just 15% of the statewide market. I've run an unweighted average for the other five carriers, and blended that with the first five for a semi-weighted average rate hike of just 0.8% overall.

I know this is an imperfect way of doing it, but it's the best I can do at the moment. I hope to have more complete data once the approved filings are made available.

New Jersey is an important state to watch, as they (along with DC) are the first state to specifically reinstate the ACA individual mandate penalty at the exact same levels as the just-zeroed out federal version. Massachusetts has a mandate penalty in place this year as well, but a) theirs pre-dated the ACA and was simply dusted off again and b) theirs uses a different formula anyway.

Last year, Individual Market insurance carriers in New Jersey announced that average unsubsidized 2019 premiums would be reduced by an average of 9.3% statewide due to two laws put into place by the state legislature and Governor Murphy: Reinstatement of the mandate penalty at federal levels (which lowered rates by 6.8 percentage points from +12.6% to just +5.8%) and the initiation of a solid reinsurance waiver program (which reduced rates by a further 15.1 points, for a final average change of -9.3%).

Unfortunately, North Dakota is another state where the carriers have redacted their rate filings. I was able to garner some info about one of the three carriers participating in the Individual Market next year: Medica's filing redaction wasn't done properly, so I was able to extract that they're looking at medical trend of 7.7%, a morbidity reduction of 1.5%, a 2.3% increase due to the reinstatement of the ACA's insurer fee...and a 20% reduction due to the implementation of the state's reinsurance program, which I first reported on last fall and followed up with this spring.

Sure enough, a week or so ago it was made official:

(sigh) I'm into the home stretch with only a handful of states left to go. Unfortunately, South Carolina is yet another state where the actual enrollment numbers are either missing or redacted, making it impossible to run a properly weighted average...but again, the range between the three carriers offering individual market policies is so narrow that it doesn't make much difference anyway (between -3.72% and +0.17%).

The unweighted average is a 1.9% reduction in unsubsidized premiums statewide.

On the small group market, however, average 2020 premiums are jumping by double digits: 11.1%.

Oklahoma has three carriers on the Individual Market these days. Once again, all three rate filing memos are redacted, but I was able to dig up the number of current policy holders for one of them (CommunityCare HMO).

I've bumped that number up a bit to account for the total number of covered lives to an even 2,000. For the other two carriers, I'm assuming Blue Cross Blue Shield still holds the lion's share of enrollees and that the total on+off-exchange market is around 187,000 people.

If this is all correct, the weighted average rate increase for unsubsidized enrollees is around 1.4% statewide.

Meanwhile, the unweighted average rate hike for the small group market is 6.5%.

Not much to say about Mississippi this year...they still have two carriers on the individual market, and while they do have a whole website/database set up specifically to track and report health insurance premium changes, it's messy and only appears to post the rate filings after they've been approved, which won't be for another couple of months.

As a result, I have no idea what the relative market share is between the two and am assuming they're roughly even. Even if they aren't, the requested rate changes are so close it doesn't make much difference anyway (2.3% and 3.0%). If approved as is, unsubsidized Mississippians can expect to pay about $200 more total next year.

On the small group market, there's five carriers; again, I don't know the market share of any of them, so the unweighted average increase is 6.2% statewide.

Massachusetts, which is arguably the original birthplace of the ACA depending on your point of view (the general "3-legged stool" structure originated here, but the ACA itself also has a lot of other provisions which are quite different), has ten different carriers participating in the individual market. MA (along with Vermont and the District of Columbia) has merged their Individual and Small Group risk pools for premium setting purposes, so I'm not bothering breaking out the small group market in this case.

Getting a weighted average was a bit tricky. On the one hand, only one or two of the rate filings included actual enrollment data. On the other hand, the Massachusetts Health Connector puts out monthly enrollment reports which do break out the on-exchange numbers by carrier. This allowed me to run a rough breakout of on-exchange MA enrollment. I don't know whether the off-exchange portion has a similar ratio, but I have to assume it does for the moment.

Huh. This is interesting...after a couple dozen states with near-flat or even reduced 2020 premiums, Louisiana is just the third state I've come across where the carriers are seeking double-digit rate increases for next year.

There's actually only 3 carriers offering individual market plans in Louisiana, but there's seven listings because two of the carriers have broken out their submissions into several different product lines. Overall, HMO LA, LA Health Service & Indemnity (Blue Cross Blue Shield of LA) and Vantage Health Plan are requesting average premium increases of 11.7% statewide.

I should note that there's also one odd listing (see second screenshot below), from UnitedHealthcare. It claims to be for off-exchange ACA-compliant individual market plans, but two things about it make no sense:

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