Consumers in New York have the chance to comment on requested premium increases in the individual and small group health insurance markets. The applications, where insurers justify their requests, are available through the New York State Department of Financial Services (DFS) (you can submit comments online here; see below for direct links to each individual application). Comments are due by July 1.

This process is called prior approval because in New York, the state must approve the changes insurance companies want to make to their premiums ahead of time. DFS reviews the applications to make sure that premium increases are linked to actual increases in costs, instead of things that insurers could do better at controlling.

In the individual market the average request was 24 percent this year. Insurers attribute half of the increase (11.9 percent) to price increases sparked by the repeal of the individual mandate. The more customers in the market, the lower the premiums – the mandate encourages people to buy insurance, so losing it means fewer customers and higher prices. The average requested increase was only 7.5 percent in the small group market, which is unaffected by the individual mandate repeal. Some insurers are also asking for an increase to manage the federal government’s refusal to make cost-sharing reduction payments (though it is unclear how appropriate this is since most of New York’s insurers already received an increase for this reason last year).

DFS takes its regulatory duties seriously, and they want to hear from consumers about what it means for their families when premiums go up year after year. Last year, DFS reduced the requests by 3.8 percent in the individual market (saving customers $59 million) and by 2.4 percent for the small group market (saving customers $166 million).

HCFANY submits detailed comments every year – you can see the types of arguments we make in our letters from 2017 (link) and 2016 (link). However, consumer comments do not require as much detail as HCFANY provides. If you decide to comment, you can simply provide the name of your insurance company and plan and discuss how a rate increase would affect you. What changes would you have to make if your insurance company was allowed to increase their rates? Will you still buy insurance? We’ve written some longer instructions if you want more guidance (link), but the important thing is to speak frankly about your own experiences.

Comments are posted publicly. That means your comment won’t just inform DFS; it will be part of the bigger conversation occurring about the affordability of health care in New York. Consumers are not a big enough part of those discussions – we should take advantage of every chance we get to change that!

Individual Market Applications

Direct links are provided below for each insurance carrier that participates in New York’s individual market through our health insurance exchange. The narrative summary is a short (under ten pages) explanation for why the insurance company thinks it has to raise rates. The full applications are very long but links are provided for those who want to examine them more closely.

• CDPHP: Narrative Summary (link), Complete Application (link)
• Empire: Narrative Summary (link), Complete Application (link)
• Excellus: Narrative Summary (link), Complete Application (link)
• Healthfirst PHSP: Narrative Summary (link), Complete Application (link)
• HIP/Emblem: Narrative Summary (link), Complete Application (link)
• NYHQC/Fidelis: Narrative Summary (link), Complete Application (link)
• HealthNow: Narrative Summary (link), Complete Application (link)
• Independent Health: Narrative Summary (link), Complete Application (link)
• MetroPlus: Narrative Summary (link), Complete Application (link)
• MVP Health Plan: Narrative Summary (link), Complete Application (link)
• Oscar: Narrative Summary (link), Complete Application (link)
• Unitedhealthcare of New York: Narrative Summary (link), Complete Application (link)