Category Archives: Rate review

Winter is coming?

For the past year or so, ACA proponents have gloated over the fact that markets have not yet collapsed in a death spiral and that enrollment in Exchange plans has grown to 9 million.  There are at least four recent developments, however, that suggest the ACA is in greater trouble than many realize.

Enrollments Way Lower Than Projected

The first piece of troubling news comes from CMS itself: Notwithstanding the full implementation of the individual mandate, CMS is projecting anywhere from 9.4 million to 11.4 million people enrolled in the Exchanges, an increase of 3-25% over its figure for 2015.  And, while ordinarily growth rates of this nature might please insurers, the projections on the basis of which Obamacare was enacted asserted that 21 million would be in the Exchanges by 2016.  Thus, while the Exchanges were running at 70% of original projections in 2015, they are now projected to run at just 45 – 52% of projections for 2016.  Moreover, between 0.9 million and 1.5 million of the enrollees for 2016 are projected to come  not from the uninsured but from those already holding off-Exchange individual market policies.

The new projection
The new projection
The premise on which the ACA was enacted
The premise on which the ACA was enacted

The reduced enrollment in the Exchanges has several ramifications. First, it likely means the pool in the Exchanges is less healthy on average than expected. Second it means the significant overhead expended in establishing the Exchanges and running them is spread over a lot fewer people. And third it means that Obamacare was essentially passed on greatly exaggerated assertions of its benefits.  Does the extraordinarily elaborate and expensive apparatus is establishes make sense when the a far lower than projected number of people gain health insurance of quality? One also must wonder how the dilution of the individual mandate through various “hardship exemptions” may have lowered the number of people enrolled on the Exchanges.

[[Added 10/20/2015]] For an excellent analysis of this issue, look also at Brian Blase’s recent article in Forbes. (http://www.forbes.com/sites/theapothecary/2015/10/19/examining-plummeting-obamacare-enrollment-part-i/)

Footnote 1: CMS is now “unable” to make projections for the SHOP Exchanges.  Are we now prepared to call them a bust?

Footnote 2: It is not clear whether the CMS enrollment projections took into account the very substantial gross and net premium that appear to be coming (see below).

More Coops Closing

The second piece of disturbing news is that at least four more coops insuring a significant number of people on the Exchanges are going out of business.  They are as follows:

Health Republic Insurance of Oregon (10,000 members; $50 million startup “loan”). By the way, Dawn Bonder, CEO of Health Republic, was quoted in The Oregonian just a month ago as follows: “We are strong and we are sticking to our plan, which has always been slow and steady growth. We’re very financially stable,” Bonder said. “We see a long,healthy life in front of us.”

Colorado HealthOP (83,000 members; $72 million in startup “loans”).  According to the Denver Post, this comes after the coop increased its enrollment seven-fold and captured 39% of the market in Colorado by cutting rates in 2015 (notwithstanding losses the year before).

Kentucky Health Cooperative (51,000 members; $146 million in federal loans, with a $65 million “emergency solvency loan” in 2014).  Again, this coop managed to capture 75% of the Kentucky Exchange market by offering insurance at lower prices.  Before shutting down, it had requested a 25% increase in premiums for 2016.  By the way, anyone remember those stories about how Kentucky was the success poster child for the ACA? It looks like its success may have been built primarily by selling insurance at cut-rate prices hoping that most of the losses would be bankrolled by the federal government.

Tennessee Community Health Alliance (27,000 members; $73 million in federal startup loans).  How had this coop captured market share?  Apparently by charging premiums so low that, as reported by The Tennessean, it had to request a 32% increase for 2016 and was granted/directed — get this — to offer premiums at a 45% higher rate.

Many of the coops blame their failure on the Cromnibus law enacted in December of 2015 that prohibited use of non-appropriated funds to pay for the federal Risk Corridors program that, on paper, was supposed to have the federal government backstop up to 80% of losses.  Given the magnitude of insurer losses thus far, the federal government is thus able to pay only 12.6% of the obligations created on paper by this program.  If one assumes, however, that the coops are correct in blaming Risk Corridors rather than mismanagement for their failure, this would confirm the suspicions of many that insurers priced their policies deliberately low in order to bring in business, relying on the federal taxpayer to cover their losses. I would also not be surprised to see some sort of legal action relating to coops who, notwithstanding Cromnibus and the handwriting on the wall persisted in booking Risk Corridor receivables at full value until very recently.

There will surely be lots of finger pointing over the failure of these coops: Democrats pointing to the “evil” Cromnibus bill as the source (although many Democrats voted for the legislation) and Republicans pointing to the inherent flaws in the ACA as the root of the problem. In the meantime, however, in many states, one of the sources of lower-priced insurance has been eliminated, meaning that many will be seeing substantial increases in gross premiums.

The fall of the PPO?

One of the promises of the ACA was that it would continue to offer choice to consumers and that they would be able to keep their doctor.  Not so in many states.  Plans that offer greater degrees of choice in selecting one’s provider appear to be in some trouble, closing in the shadow of an impending adverse selection death spiral. In Florida, for example, zero PPOs will now be available on the Exchanges in 2016.  In Texas, the state’s largest insurer, Blue Cross and Blue Shield, has announced that it lost so much money on individual PPO plans that it will no longer sell any in 2016. This development means 367,000 people will have to find other types of plans. In Illinois, Blue Cross is continuing PPOs for now, but only with narrower networks than had been available under a plan that had served 173,000 individuals.

I suspect this is just the beginning of problems for PPOs sold on the individual market in an era when insurers can not medically underwrite.  Between 2014 and 2015, PPO premiums went up at a far higher rate than other plan types.  We will shortly have the data to see whether this trend continued in 2016.

Rates

We don’t have all the information yet, but if ACA proponents like Charles Gaba are correct, we are looking at some substantial gross premium rate hikes in the United States, and extremely high rate hikes in some states.  What Mr. Gaba has done is to go state by state through various filings and do what no one else has tried: correlate premium rates with actual enrollments.  Although I do not always agree with Mr. Gaba, I must praise him for a very worthy and time consuming enterprise. The fact that some insurer is charging an astronomical premium for insurance doesn’t mean as much when few people are buying their product as it does when an insurer is getting a large share of the business.  Unfortunately, the federal government does not publish in any place I can discover insurer-by-insurer breakdowns of enrollment.

The research suggests gross premiums will go up 12.45% nationwide once enrollment weighting is taken into account.  Statewide figures range from a high of 41.4% in Minnesota, 39.0% in Alaska, and 30% in Hawaii to lows of 0.7% in Maine, 0.7% in Indiana and  3.5% in Connecticut.  Among the bigger states, the estimates are 4% for California, 15.8% for Texas, 9.5% in Florida, and 7% in New York. As I have noted on this blog and in testimony before a Congressional committee, net premium increases — which is what really matters to purchasers — can often be considerably greater than these figures, particularly for poorer individuals, but also can be lower.

 

More to come

We will, of course, see what plays out.  But for those who thought the brilliant engineering of Obamacare had forever slain the adverse selection dragon, beware. Dragon eggs can hatch.

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Is Minnesota the canary in the coal mine?

We will have a fuller picture in a few weeks when the federal government is supposed to release the premiums and plans available on heathcare.gov, which serves about 34 states, but if Minnesota is representative, there are signs that the ACA is entering a dangerous phase. That state has posted its rates for 2016 already. It’s not pretty. Gross premiums for policies sold on its Exchange will go up between 14% and 49%.  Net premiums will go up more than this or less than this depending on the income of the subscriber.

The table below shows the average rate increases for 2016 among the insurance carriers selling on MNSURE, Minnesota’s health insurance exchange. The data is simply copied from its website.

Untitled-1

The spreadsheet shown below indicates gross and net premiums for a 40 year old individual residing in Minneapolis, earning $25,000 per year and selecting a silver plan.  The rate increases contained there make the simplifying assumption that each insurer applied its average rate increase to the listed plans.  We don’t have actual plan-by-plan data that would enable us to provide a better estimate.  Here, the net premiums assume that the individual is deemed able under to contribute about $136 per month to the premium.  As one can see the the net premiums go up between 2015 and 2016 by -7% for a few of the Medica plans to up to 36% for the more expensive Blue Cross plans.

Minnesota_MNSURE25k

If we reduce the income of the purchaser, the net premium increases can grow.  Here, we take our same 40 year old but cut his income down to $18,000.  The individual is (somehow) supposed to be able to contribute about $62 a month for a policy. Now the net premiums for the silver plans swing more dramatically, going from -15% for one of the Medica plans to 61% for one of the Blue Cross plans.

Minnesota_MNSURE18k

Is Minnesota representative?  Not entirely.  It is probably at the high end of premium increases in part because its premiums were unusually low in 2015.  But if other states experience rate hikes anything like Minnesota, we will see healthier individuals search out alternatives or start to be more creative about hardship exemptions in the event they decide that insurance under the ACA is just too expensive. Either way, there is beginning to be a significant risk of the exchange markets unraveling.

 

 

 

 

 

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Why net premium increases will often be even larger than you think

I’ve written before that net premium increases for many individuals purchasing policies under the ACA will be higher than gross premium increases.  I’ve gotten some emails expressing puzzlement over this conclusion.  So, in this post I want to explain in some detail why this is the case.

An example

Consider five Silver policies on an Exchange. In 2015, here is a table showing their gross premiums

1. $4,161.55

2. $3,881.27

3. $4,338.10

4. $4019.11

5. $3550.64

So, the second lowest silver policy is Policy 2, which has a premium of $3,881.27. Suppose our individual can contribute $1,000 per year based on their income.  If they had purchased policy 2 their tax credit would have been $2,881.27 and their net premium would have been $1,000.  If our individual purchases policy 4, however, which has a gross premium of $4,019.11, their tax credit is still $2,881.27, so they will end up having a net premium of $1,137.84

Now, suppose the gross premium increases average about 6.33% but are distributed as follows among our 5 insurers.

1. 11.38%

2. -2.57%

3. 7.26%

4. 10.28%

5. 5.29%

The new gross premiums for 2016 are thus as follows:

1. $4,634.99

2. $3,781.70

3. $4,652.87

4. $4,432.30

5. $3,738.41

The new second lowest premium is Policy 2, which has a gross premium of $3,781.70.  Suppose now our individual has essentially the same income such that the amount they are deemed to be able to contribute is still $1,000.  This means the 2016 tax credit is $2,781.70. What if our individual wants to keep his health plan and stick with Policy 4. Maybe our individual likes the practitioners in the Policy 4 network.   The new difference between the new gross premium for Policy 4 ($4,432.30) and the tax credit of $2,781.70 is $1,650.60.

Thus, although the gross premium for the policy has gone up 10.28% (bad enough) the net premium has gone up 45.06%.

So, did I concoct some bizarre set of numbers so that the ACA would look bad?  I did not. The result you are seeing is baked into the ACA.

An experiment

Let’s run the following experiment.  Suppose premiums are normally distributed around $4,000 with a standard deviation of $500.  And suppose the gross premium increase is uncorrelated with premiums and is normally distributed around 5% with a standard deviation of 5%.  Assume there are five policies at issue. We can then calculate for each of the five policies,  the gross premium increase and the net premium increase in the same way we did in the example above. We run this experiment 100 times.

The graphic below shows the results. The horizontal x-axis shows the size of the gross premium increase (in fractions, not percent).  And the vertical y-axis shows the size of the net premium increase. The dotted line shows scenarios in which the gross premium increase is the same as the net premium increase.  What we can see is that for the larger gross premium increases, the net premium increases tends to be larger than the gross premium increases and for the smaller gross premium increases (or for gross premium decreases), the net premium increase tends to be smaller than the gross premium increase. Thus, about half the population will experience net premium increases larger — and sometimes way larger —  than they might think from reading the news.

grossvnetpremiums

 

Is this result an artifact of, say, having our policyholder being deemed by the government to be able to contribute $1,000 based on their income?  Not really.  The graphic below runs the same experiment but this time assumes our individual is poorer and is thus deemed able to contribute only $500.

grossvnetpremiums500

What we can see from the graphic is that the result is even more dramatic.  The poor will see drastic divergences between gross premium increases and net premium increases. Many, for example who have gross premium increases of say just 5% experience net premium increases of over 30%.

And what of the less subsidized purchasers, those who, for example, are deemed able to contribute $3,000 towards a policy?  The graphic below shows the result.

grossvnetpremiums3000

Now we can see that the gross premium increases and net premium increases are clustered pretty tightly together.  Indeed, for the wealthier purchasers, net premium increases more often than not are smaller than gross premium increases.  However, since most purchasers of Exchange policies tend to be those receiving large subsidies, the graphic above is not representative of the situation for most purchasers.

Did I rig the result by assuming that the income-based contribution stayed the same.  No.  Here’s a graphic showing gross versus net premiums first, under the assumption that income-based contributions remain the same and second, under the assumption that income-based contributions wander, sometimes going up, sometimes going down.

grossvnetpremiumsdynamicContribution

 

What you can see is there is not much difference between the yellow points — income based contribution remains the same — and the blue points — income based contribution wanders.

And, although I won’t lengthen this post with yet more graphics, the basic result generalizes to situations in which there are more than 5 Silver policies.  The pattern is the same.

Conclusion

It really is true. Net premium increases will often be larger than gross premium increases, particularly for the poor. The sticker shock some received on seeing the gross premium increase figures recently released at healthcare.gov will, in many instances, be little compared to the knockout blow that will occur when people start computing their new net premiums.

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No, New York Times, “guesswork” is not the reason ACA premiums are rising

The New York Times, whose editorial board has long been a strong supporter of the Affordable Care Act, published an article on its front page yesterday in which the headline read, “Seeking Rate Increases, Insurers Use Guesswork.” And, lest there be much doubt that the article suggested that speculation — the sort that regulators might understandably reject as a basis for premium hikes — rather than hard facts were leading to the frightening premium hikes, here are some quotes selected by author Reed Abelson for publication:

“But many insurers, including those seeking relatively hefty increases below 10 percent, say they are asking for higher premiums because they remain unsure about the future and what their medical costs will be.”

“It’s the year of actuarial uncertainty, and actuaries are conservative,” said Dr. Martin Hickey, chairman of the National Alliance of State Health CO-OPs and the chief executive of the New Mexico exchange. “The safest thing to do is to raise rates.”

Yes, to be sure, there was the suggestion in other parts of the article that higher than expected claims were part of the problem, but both the headline and remaining comments suggest that the high rates of increase were the result of unsupported speculation.

Wrong, New York Times! If you actually read the justifications for the premium increases submitted by insurers and their accompanying actuarial memoranda, you can see there are two dominant themes: (1) higher than expected claims expenses and (2) diminution of federal subsidies to the insurance industry.  You can also see lengthy memoranda containing facts and figures explaining their experience last year and the basis for their trending those experiences into the future. And, while one need not invariably take the insurance industry at its word or at face value, this is an instance where they have to make the best case possible for their rate increases. Regulators will scrutinize insurers’ work. Misstatements or rank guessing would seem to be against the insurance industry’s interest.

So instead of quoting people, who might themselves be guessing, let’s look at what the insurers actually said. I am going to bore you with 17 representative filings from across the nation. I do so because I want to make clear that the evidence is overwhelming. Most of these are contained in or accompanied by lengthy memoranda containing elaborate tables justifying the increases. I’ve attempted to be diverse in my selection of insurers to avoid repetition of, for example, the Blue Cross position or the Aetna position.

1. Blue Cross and Blue Shield of Alabama

BCBSAL proposes an average 28% increase to rates for the products offered in 2015. The main drivers of the need for a rate increase are as follows:

• Single risk pool experience which is significantly more adverse than that assumed in current rates

• Medical inflation and increased utilization as indicated in Section 5: Projection Factors

• Expected increases in the average population morbidity of the Individual Market, also described in Section 5: Projection Factors

• Reinsurance program changes, described in Section 9: Risk Adjustment and Reinsurance

BCBSAL determined that the following items did not contribute significantly to the need for a rate increase:

• Taxes and fees: Minimal changes in the amount needed for taxes and fees, described in Section 10: Non-benefit Expenses and Profit & Risk

• Benefit changes: No changes to offered benefits for 2016

2. HealthNet of Arizona

The projected claims experience was developed using calendar year non-grandfathered 2014 experience. If our rate request is approved, the expected premium for the entire risk pool is $313.91 PMPM. This represents an increase of 24.7% in average premium. 2014 premiums received were $127,867,744. Claims paid were $171,764,569. Since 2014 medical costs are increasing with an annual trend of 5.5%. Prescription drug costs are increasing with an annual trend of 10.3%. Claims costs are 85.1% of premium. Administrative costs are 14.5% of premium. Profit is -4.8% of premium.

3. Cigna Health and Life Insurance Company (Connecticut)

The most significant factors requiring the rate increase are:

Changes in Medical Service Costs: The increasing cost of medical services accounts for the majority of the premium rate increases. Cigna anticipates that the cost of medical services in 2016 will increase over the 2015 level because of prices charged by doctors and hospitals and more frequent use of medical services by customers.

Transitional Reinsurance Program Changes: The federally mandated transitional reinsurance program is in effect for three years (2104, 2015, and 2016). The amount of funding available to issuers under the reinsurance program to offset adverse claim experience decreases each year ($10B in 2014, $6B in 2015, and $4B in 2016). Additional premium is required to compensate for the reduced reinsurance support in 2016.

Morbidity (Risk Pool) Adjustments: The marketplace for non-grandfathered individual plans is affected by provisions of the Patient Protection and Affordable Care Act (the Affordable Care Act) that became effective in 2014, including:
guarantee issue and renewal requirements
modified community-rating requirement
federal premium subsidies for low and moderate income individuals.

The effects of these 2014 changes when coupled with previous regulatory changes and overall utilization experienced in 2014 suggest that it is appropriate to increase the overall claim level assumption reflected in the premiums for individual plans in Connecticut.

4. Aetna Health, Inc. (Florida)

Why We Need to Increase Premiums
Medical costs are going up and we are changing our rates to reflect this increase. We expect medical costs to go up 10%. Medical costs go up mainly for two reasons – providers raise their prices and members get more medical care.
For policies issued to individuals in Florida, some examples of increasing medical costs we have experienced in the last 12 months include:
· The cost for an inpatient hospital admission has increased 8.0%.
· The average cost for outpatient has increased 8.4%.
· Costs for pharmacy prescriptions have gone up 8.0%.
· The use of outpatient hospital services has increased 4.5%.

What Else Affects Our Request to Increase Premiums
Several requirements related to the Affordable Care Act (ACA) impact these rates. These include:
· “Keep What you Have” and its impact on the population that will enroll in the plans covered by this filing
· Enhanced network access standards – which limit our ability to control the cost and quality of medical care
· Changes to required taxes and fees
· Phase-out of the Transitional Reinsurance Program which increases rates for plans issued to individuals

5. Humana Employers Health Plan of Georgia, Inc. (Georgia)

Many factors influence this rate calculation. The primary factors include
‐ Population health‐ Expected changes in the aggregate health level of all individuals insured by all carriers in the individual health insurance market.
‐ Claims cost trend‐ Changes in expected claims costs associated with changes in the unit cost of medical services, changes in Humana’s contracts with hospitals, physicians, and other health care providers, and the increase or decrease in utilization of medical services including changes in the severity and mix of services used.
‐ Plan Changes‐ Changes to plan designs due to changes in federal requirements.

6. Wellmark Health Plan of Iowa, Inc. (Iowa)

Reason for Rate Increases The effective average rate increase for these products is 28.7%, varying by plan as listed in the table above. The primary drivers of the proposed rate increases include, but are not limited to:

• Adverse Experience/Risk Adjustment Transfer: The risk of the market is more adverse than what we had assumed in the current rates; which leads to a significant projected risk adjustment transfer payment to other carriers.

• Medical and Drug Inflation: Both increased utilization and increased cost per service/script contribute to projected claims trend.

• Phase out of Federal Transitional Reinsurance Program: As this program phases out over three years, the expected receivables from this program are smaller for 2016 than they were for 2015.

7. CareFirst of Maryland (Maryland)

The main driver of the financial performance of these products and the proposed rate increase is the very significant increase in average morbidity between 2013 (the pre-ACA pool which underwent underwriting) and 2014 (the post-ACA guarantee-issue pool). The allowed claims per member per month (PMPM) increased from $197 in 2013 to $391 in 2014, a much higher and faster increase than anticipated.

8. HealthPlus Insurance Company

The biggest driver of rate change is 2014 claims experience that is more adverse than assumed in current rates. Another driver is due to the lower Federal reinsurance recoveries.

9. Coventry Health & Life Insurance (Missouri)

Why We Need to Increase Premiums
Medical costs are going up and we are changing our rates to reflect this increase. We expect medical costs to go up 9.4%. Medical costs go up mainly for two reasons – providers raise their prices and members get more medical care.

What Else Affects Our Request to Increase Premiums
We offer individuals in Missouri a variety of plans to choose from. We are changing some benefits for these plans to comply with state and federal requirements.
Several requirements related to the Affordable Care Act (ACA) may also impact these rates. These include:
• Changes to our expected projected average population morbidity and its relationship to the projected market average for risk adjustment.
• Changes to required taxes and fees
• Phase-out of the Transitional Reinsurance Program which increases rates for plans issued to individuals

10. Aetna Health Inc. (Nevada)

Why We Need to Increase Premiums
Medical costs are going up and we are changing our rates to reflect this increase. We expect medical costs to go up 10.6%, excluding the effect of benefit changes described below. Medical costs go up mainly for two reasons – providers raise their prices and members get more medical care.

For Individuals in Nevada, some examples of increasing medical costs we have experienced in the last 12 months include:
• Primary Care Physician visits have increased by 124.2%.
• Inpatient bed days have increased by 51.0%.
• Expenses for emergency treatment have increased 22.7%.

What Else Affects Our Request to Increase Premiums
A prominent hospital system in Nevada moved from participating to non-participating in 2014 and is expected to stay that way into 2016. This has an adverse impact on claims costs since the more favorable lower-cost in-network reimbursement rates no longer apply.

Several requirements related to the Affordable Care Act (ACA) also impact these rates. These include:
• Enhanced network access standards – which limit our ability to control the cost and quality of medical care
• Changes to required taxes and fees
• Phase-out of the Transitional Reinsurance Program which increases rates for plans issued to individuals

11. Blue Cross Blue Shield of New Mexico (New Mexico)

[E]arned premiums for all non-grandfathered Individual plans during calendar year 2014 were $84,497,659, and total claims incurred were $105,605,811.

After application of the ACA federal risk mitigation provisions, the total BCBSNM Individual non-grandfathered block of business experienced a financial loss of 17% of premium in 2014.

The proposed rates effective January 1, 2016, are expected to achieve the loss ratio assumed in the rate development.

Changes in Medical Service Costs:

The main driver of the increase in the proposed rates is that the actual claims experience of the members in these Individual ACA metallic policies is significantly higher than expected. After application of the ACA federal risk mitigation provisions, the total BCBSNM ACA block of business experienced a loss of 19% of premium in 2014.

12. Medical Mutual of Ohio (Ohio)

Medical Mutual of Ohio is proposing an overall rate increase of 16.9% for plans effective January 1, 2016. This increase will potentially impact the 37,673 existing MMO members. The rate change ranges from 7.4% to 26.0%, varying by plan, age, change in tobacco user status, change in family composition, and the geographic area where the member resides.
The experience of MMO Individual ACA plans was not favorable in 2014. MMO has paid nearly $167 million claims and only received $114 million in premium. In 2014, MMO lost about $42 million dollars on its individual ACA business alone. With the rate increase implemented for 2015 and proposed for 2016, MMO’s experience is expected to improve, becoming profitable in 2016.
The following items are the main drivers for the proposed rate increase:
1. The transitional reinsurance recovery decreased from the 2015 level and will have a smaller impact offsetting the total claims.
2. The increase in the medical and drug cost is about 6.2% annually. Out of that increase, 40% is due to the change in unit cost, 31% is due to the change in utilization and the rest is due to the change in the mixture of services.
3. We expected the morbidity and demographics to improve in 2016 due to increased penalty of non-compliance, a greater understanding of the ACA law, and a reduction in the amount of pent-up demand for services. This alleviates the rate increase needed based on the experience.
4. There’s no changes in benefit from 2015 to 2016.
5. The administrative cost and commission will decrease $2.51 per member per month. The profit and risk will increase $7.92 per member per month. The taxes and fees will increase $4.51 per member per month.

13. Geisinger Quality Options (Pennsylvania)

Geisinger Quality Options has proposed an overall base rate increase of 58.36% for Individual PPO members renewing in the Marketplace effective January 1, 2016 through December 1, 2016. The overall increase is largely due to the claims experience in ACA compliant individual market plans being much higher than what was assumed in current rates. Other contributing factors include annual claims trend, federally-prescribed ACA fees and reduced benefits in the Transitional Reinsurance Program.

14. Pacific Source Health Plans (Oregon)

This filing requests an aggregate increase of 42.7 percent over the rates approved in our 2015 Oregon Individual filing. The proposed rates are based on PacificSource’s historical Oregon Individual claims experience adjusted for PacificSource’s historical average risk compared to the market average risk, anticipated medical and pharmacy claims trend, expected change in market morbidity from 2014 experience period to 2016 projection period, changes in benefits, and expected state and federal reinsurance recoveries. The proposed rates also reflect changes in the taxes and fees imposed on health insurers for 2016. The range of rate increases is 23.4 percent to 60.4 percent and impacts PacificSource’s 8,216 Oregon Individual members. The variation in rate increases is driven by some changes in benefits i.e. copays, deductibles, OOP max, as well as adjustments to geographic area factors. The overall average impact of benefit changes on the requested rate increase is 0.0 percent.

The increase in rates from 2015 to 2016 is primarily driven by a dramatic worsening of claims experience in 2014 as compared to 2013, and the reduction of expected reinsurance recoveries in 2016. Note that this is the first rate filing where a full year of post ACA experience data was available. This data shows that the overall increase in morbidity from PacificSource pre ACA experience to post ACA market experience is much greater than originally projected in our 2014 and 2015 rate filings. The combined medical and pharmacy annual trend used in this filing is 7.0 percent, which reflects expected changes in costs, changes in utilization, and the impact of leveraging. The primary driver of the annual trend assumption is specialty drug cost and utilization, particularly Hepatitis C drugs. Administrative expenses and margin are budgeted to decline compared to the 2015 rate filing.

Over the calendar year 2014, the Oregon Individual block earned 30.2 million in premium and incurred an estimated 50.0 million in claims, for a raw medical loss ratio of 165.2 percent. Premium and claims expenses are shown before the impact of reinsurance, risk adjustment, and risk corridor. At this time we do not expect risk corridor payments to be made to issuers. After expected risk adjustment and state and federal reinsurance recoveries, we estimate a 2014 loss ratio of 116.5 percent. Combined administrative expenses, commissions, taxes, and assessments were approximately 24.6 percent of premium.

15. Scott & White Health Plan (Texas)

The Scott & White Health Plan is requesting an average rate increase of 32.3% to the Individual HMO Rating Pool. There are 24,294 covered individuals as of January 2015. 10.0% of the 32.3% increase is due to health care cost inflation, 14.3% of the increase pertains to changes in Risk Adjustment and Reinsurance assumptions, 2.7% is due to changes in fees, and the remaining 5.3% is due to actual and expected unfavorable experience.

16. Optima Health Plan (Virginia)

The rate increase is the same for all members in the same plan. Where the 2016 plan is different than the 2015 plan these members will be automatically enrolled into the 2016 plan shown. Premium rates are effective January 1 2016.
Claims expenses were very high in 2014 relative to earned premium. However payments from the federal transitional reinsurance and risk adjustment programs are expected to help significantly.
The federal reinsurance program is only temporary and while it is continuing into 2016 the amount of reinsurance per claim is less than in 2014 and 2015. As such premium rates will be increased to account for this impact. Additionally the risk adjustment program alone does not appear to provide sufficient relief to enable the Company to meet its pricing targets.
It is anticipated that 2014 had some amount of higher claims due to new members having pent-up demand for services and less healthy people tending to be the first to sign-up for ACA-compliant plans given the new rating and underwriting rules. Because of this we do not assume that 2016 will necessarily be as high a claim level as seen in 2014 but some of what has been experienced will remain.
These reductions from 2014 levels will be countered by upward pressure on costs from other sources such as medical trend as described below.
The proposed rate increase is intended to account for expected claims activity in 2016 given historical experience and changes in morbidity as well as any expected assistance from the federal reinsurance and risk adjustment programs. With the proposed rate increase the anticipated loss ratio is 80 percent.
Medical trend for these products is anticipated to be an average of 7 percent per year on paid claims for example after member cost sharing or a total of 14.5 percent over the period from 2014 to 2016. This was developed based on historical experience as well as consideration for information available on general medical inflation trends. Medical trend includes a combination of utilization and costs of services. This increase in cost is included in the calculation of the rate increase.

17. Security HealthPlan of Wisconsin (Wisconsin)

The biggest driver of the rate change is SHP’s underlying claims experience used in developing the projected index rate. We used SHP’s 2014 individual non-grandfathered, ACA allowed claims as the basis for claim development. The 2014 claims and membership distributions indicate experience is worse than we priced for in 2015 rates. Further, based on a Wisconsin risk score analysis conducted by Milliman, we are projecting no risk adjustment transfer payment. This assumption of no payment results in higher rates in 2016 since we had projected SHP would receive money from the risk adjustment pool when developing the 2015 rates.

Another driver of the rate change is due to the lower federal transitional reinsurance recoveries in 2016. The recoveries assume in 2016 SHP will receive 50% of all SHP’s individual members’ per member per year incurred claims between $90,000 and $250,000. In 2015, rates were priced assuming recoveries to be 50% of claims between $70,000 and $250,000 based on the federal parameters in place at the time of pricing.

The projection of claims from the experience period to the effective period assumes 5.0% annual medical and drug trend. These trends were estimated based on data from SHP, conversations with SHP senior management, Milliman research, general industry knowledge, and our judgment of recent trends.

Conclusion

So, does this sound like “guesswork” to you?  It does not to me.  All of these insurers are lying or mistaken about what is causing their requests for premium hikes? I don’t think so.  Of course, there is “trending” in which insurers approximate how previous increases will continue to the future and this requires some art on the part of insurers.  Of course, insurers may want to present their requests for rate hikes in a way more likely to be approved. But what they have presented is no more “guesswork” here than the work of any insurer in setting rates for almost any form of insurance. It is the sort of actuarial projections that are generally approved by regulators.

Health insurers now have a decent feel what it is going to cost them to participate in Obamacare.  And these insurers have a pretty common perspective: the whopping increase are driven by  greater utilization than expected among those electing coverage  (adverse selection and moral hazard), increases in the cost of medicine, and reduction of federal subsidies.

Exactly what some people predicted.

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Many will experience premium hikes even larger than requested rate increases

Yesterday, the federal government released its list of proposed gross premium increases for health insurers selling policies on the Exchanges. To many, particularly supporters of the ACA, the results released at healthcare.gov were jaw dropping. The median increase requested in New Mexico was 59%. In Pennsylvania, Highmark Health Insurance, the state’s “Blue Cross” insurer requested rate increases on many of its plans over 35%.  In Illinois, Coventry Health Care, an Aetna subsidiary, requested rate increases of over 30% on several of its plans. In Oregon, PacificSource, the state’s third largest health insurer, sought increases of 29% and higher on several of its plans. In short, in many states, very large increases in gross premiums were requested by a diverse set of major and minor players.

Pundits, including me, have pointed out that one should not leap from a view of these numbers to the conclusion that policyholders in the Exchange markets should invariably expect double digit increases.  The only companies in the data released yesterday are those requesting more than a 10% increase.  As Larry Levitt, a top executive at the influential Kaiser Family Foundation, said, “Trying to gauge the average premium hike from just the biggest increases is like measuring the average height of the public by looking at N.B.A. players.”

In fact, however, the math of Obamacare means that many purchasing policies on the Exchange will actually experience larger net premium increases than even the huge ones proposed by many insurers. This is so because of the way the Affordable Care Act computes the net premium paid by policyholders.

Let me take a quick example to illustrate the reason net premiums are going to go up even more than the numbers from healthcare.gov suggest.  Take an individual who has an individual policy for which the gross annual premium is $4000.  And suppose that the premium increase for that plan, as is proposed in many places, 25% up to $5,000.   But suppose that the second lowest priced plan in the state, which was also charging $4,000 goes up only 5% to $4,200.  What happens to net premiums.?  Let’s make our individual a typical Exchange purchaser with an income equal to 250% of the federal poverty level.  In 2015, that individual would be paying about $2,334 in net premiums.  In 2016, because net premiums are pegged to the price of the second lowest silver plan, that individual would be paying about $3134 in net premiums.

In short, the policyholder experiences an increase not of 25% — bad enough — but of 34%, even worse. If the policyholder wants to keep its plan, and perhaps the network of medical practitioners that have developed an understanding of the policyholder’s medical conditions, it is going to require the policyholder to pay 34% more.  To be sure there are complications that might tweak that number a bit, but the basic math is right.

It will be even worse for some.  We know that in some states, a few plans are proposing reductions in their gross premiums.  In our prior example, if the second lowest plan went down by 2%, the net premium of the plan the individual actually purchases will go up to $3414 per month, an increase of 46%.

Or, keep the assumption that the second lowest silver plan goes up by 5%, but have the purchaser have a income not of 250% of FPL but of 175% of FPL.  Policies are supposed to be affordable for them too. Formerly they would have paid $1021 per year in net premiums.  Now, they will pay $,1821 per year in net premiums, an increase of 78%. It turns out that keeping your healthcare plan is going to be an extremely expensive proposition.

So, yes, in some sense the gross premium increases released yesterday by the federal government are unrepresentatively large.  But in terms of what people actually pay, they are, in many instances, unrepresentatively small.  Of course, many people will be unwilling to pay increases of 34% or 46%  or 78%.  But to avoid those increases, they will increasingly need to flock to the second lowest silver plan.  Doing otherwise will prove ever more expensive. And so, the promise of “choice” in healthcare plans contained in the ACA may be fulfilled significantly less than its proponents anticipated when the bill was passed.  The architecture of Obamacare may induce yet more purchasers to converge on Silver HMO plans.

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Government data shows potentially scary ACA premium increases for 2016

Under the implementation of the Affordable Care Act promulgated by the Obama administration, the federal government publishes a list each June 1 of health insurers seeking to increase their premiums by over 10% from one year to the next.  Today, the Obama administration released their data for 2016. There are a lot of insurance plans and a lot of very high requested increases on the list.

My examination of the data this afternoon shows 661 insurance plans in which a rate increase of over 10% is being requested.  And the increases requested by these insurers is often way over 10%.  The median increase requested by insurers on the list it varies from a low of 12% in New Jersey to 59% in New Mexico.  Median means half the numbers are below the median and half are above the median.  Thus a median increase of 32% in Pennsylvania means that half the insurers there on the list are asking for more than a 32% increase in premiums.

An aggregation of the data is also revealing. If one looks at the median increase in each state, the “median of the median” is 19%. Half of the states are seeing median increases of less than 19% and half are seeing median increases of more than 19%.

Most of the analyses of this data thus far have looked at particular states and found them troubling.  Taken as a whole, however, the widespread significant increases should be disturbing to those who were confident that the Affordable Care Act would continue to result in low premiums.

Moreover, the median figures cited above are by no means the maximum increases requested by insurers. Let us start with some heavily populated states and take a look at some representative high increase requests.  In Texas, Time Insurance is requesting a 65% increase. In Florida, Time Insurance is asking for 63% on one of its products; the better known UnitedHealthcare is asking for 31%.  In Illinois, Blue Cross is asking for a 38% increase on one of its plans; Coventry, also a good sized player, is asking for 34% on another.  In Pennsylvania, a Geisinger plan is asking for 58%; Geisinger is a significant player in that state.  The list goes on and on.

The table

The table below shows the data I was able to mine from healthcare.gov on the rate increases.

State Number of plans reporting Median Rate Increase (Conditional on Rate Increase > 10%) Rank
Alabama 14 24 13
Alaska 13 24 14
Arizona 24 20 17
Arkansas 3 21 16
California 0 N/A
Colorado 0 N/A
Delaware 26 16 28
District of Columbia 8 14 38
Florida 13 18 25
Georgia 27 16 29
Hawaii 6 18 22
Idaho 57 19 20
Illinois 16 15 31
Iowa 30 25 11
Kansas 15 35 3
Kentucky 0 N/A
Louisiana 15 18 26
Maine 0 N/A
Maryland 8 30 6
Massachusetts 0 N/A
Michigan 12 15 33
Minnesota 0 N/A
Mississippi 6 26 10
Missouri 13 16 30
Montana 12 34 4
Nebraska 12 15 32
Nevada 25 14 36
New Hampshire 11 44 2
New Jersey 7 12 40
New Mexico 3 59 1
New York 0 N/A
North Carolina 17 26 8
North Dakota 3 18 23
Ohio 15 14 34
Oklahoma 8 28 7
Oregon 23 20 18
Pennsylvania 51 32 5
Rhode Island 0 N/A
South Carolina 10 24 12
South Dakota 18 17 27
Tennessee 12 14 35
Texas 22 26 9
Utah 31 19 21
Vermont 0 N/A
Virginia 19 14 37
Washington 24 13 39
West Virginia 14 19 19
Wisconsin 12 18 24
Wyoming 6 23 15

Caveats

All of that said, the figures should not be misinterpreted.  The following caveats must be considered.

1. The data only lists those insurers that requested an increase of more than 10%.  There are many plans that requested increases less than that amount.  So it is incorrect to say that the average or median increase in insurance prices is going to be 19%. If a lot of big insurers are requesting increases less than 10%, the average increase will be less than 19%.  On the other hand, if the big insurers are over 19% and it is mostly small insurers that are submitting rate increase requests of under 10%, then the 19% figure is too low.

2. The data is not weighted by the number of policies sold by an insurer.  With all respect to small insurers (and small states), in the grand scheme of things it does not matter much if a small insurer in a small state is raising its rates 40%.  Of course it will affect the people involved, but it is not a good bellwether of the performance of the ACA.  On the other hand, if a big insurer in a big state, like Scott & White in Texas, is requesting increases (as is the case) of 32%, that is a very big deal. Until we have an estimate of the number of policies sold by each insurer, a secret that seems to be more tightly guarded than many diplomatic communications, it is hard to know perfectly what the numbers in the list actually mean.

3. The data for some important states is missing.  We have no data for New York and California, for example, and no data from about seven other states. Does that mean that there are no insurers there requesting more than a 10% increase, that the data is just delayed, or is there another explanation?  Until this mystery is resolved, it’s hard to know fully what the numbers published today imply.

4. Ask does not equal get. All we have right now are the rate increases requested by insurers.  There now follows a review process in which the reasonableness of the rate increases are examined.  If the federal government or, in some instances, the states find the rate increases unreasonable, then they do not go into effect.  Of course, insurers who see their rate increases denied, may decline to sell the policies, which results in less competition and leaves many insureds without any continuity in coverage. Yes, it is possible that some insurers are bluffing and requesting pie in the sky.  The risk in calling that bluff by denying or modifying a rate increase is that the insurer may pull out.

5. I basically did this analysis by hand because CMS has not released the data in a form (such as Excel, CSV, JSON or others) that would facilitate machine analysis.  I tried to do the work carefully, but I am an imperfect human.  I am doubtful, however, that any errors materially affect the conclusions here.

 

 

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