Rate Review Comments are Due July 6: Read HCFANY’s Comments Here!

New York State of Health (NYSOH) has included several exciting new initiatives in its 2025 Plan Invitation. Though some of the initiatives are subject to federal approval, HCFANY is thrilled about the improvements to the quality and affordability of health insurance plans offered on the NYSOH marketplace. Here are some key wins for consumers:

  • Eliminating in-network cost-sharing for New Yorkers with diabetes in State-regulated plans. The program applies to medical care, prescription drugs, supplies, and diagnostics related to the primary diagnosis of diabetes.
  • Cost-sharing subsidies for low- and moderate-income New Yorkers on Qualified Health Plans (QHP) with incomes up to 400 percent of the Federal Poverty Level (FPL), or $125,000 for a family of four. If approved, NYSOH will use $315 million of federal waiver passthrough funding that was allocated for these subsidies in the 2024-25 State Budget.
  • Expanding maternal health cost-sharing initiatives to QHPs to allow pregnant and post-partum New Yorkers to access zero copay care for almost all diagnoses and services through 12 months postpartum.
  • Eliminating waiting periods for standalone dental plans offered through NYSOH for all adult dental services (exception for orthodontics), allowing New Yorkers to use the coverage they are paying for.

New Yorkers bracing for health insurance premiums in the individual market are in for some unwelcome news as we look ahead to 2024. According to the latest data, individual market rates are set to surge by an average of 12.4 percent next year. Health plans had initially requested a whopping 22.1 percent average rate hike for 2024, but the Department of Financial Services has managed to trim down this figure through New York’s prior approval process.

The table below presents a comparison of the health plans’ original rate hike requests and the rates that were ultimately approved, giving you insight into how the process affects your healthcare costs. (Feel free to refer to our detailed comments on each rate request.)

The prior approval process serves as a critical safeguard; however, the 12.4 percent increase still poses a financial challenge for many New Yorkers. It underscores the need for New York to explore additional measures to protect consumers from steep premium rises outside of the rate review process. States like Connecticut, Delaware, Massachusetts, Nevada, New Jersey, Oregon, Rhode Island, and Washington have already taken steps in this direction, establishing Health Care Cost Containment task forces or agencies.

For those concerned about the affordability of health insurance, there’s some relief to be found. Most New Yorkers purchasing their own health coverage qualify for subsidies that can help offset premium costs. To explore your options and find out more about available subsidies, head over to the NY State of Health enrollment site. If you need assistance with switching plans or enrolling in affordable health insurance, the Navigator program is here to help. Navigators provide free, unbiased enrollment assistance and can help you understand your eligibility for premium assistance and your coverage options. You can reach out Navigators in the CSS Navigator Network at 888-614-5400 or drop them an email at enroll@cssny.org. You can reach out to assistors with the NY State of Health online here or call at 855-355-5777.

2024 Individual Market Rate Changes   
PlanRequested IncreaseApproved IncreaseChange
Emblem/HIP52.7%25.1%-52.4%
IHBC39.2%25.3%-35.5%
MetroPlus26.4%17.6%-33.3%
CDPHP23.5%12.1%-48.5%
Highmark22.6%13.0%-42.5%
Healthfirst20.9%12.5%-40.2%
UnitedHealthcare20.9%12.2%-41.6%
Anthem (Formerly Empire HealthPlus)20.7%8.6%-58.5%
Oscar18.4%7.9%-57.1%
Excellus15.2%12.2%-19.7%
MVP13.3%6.5%-51.1%
Overall22.1%12.4%-43.9%

The Department of Financial Services released its final 2022 rate decisions today, and once again our prior approval law has resulted in huge savings for New Yorkers. Individual market insurers requested an average premium increase of 11.2% this year. After reviewing their requests, DFS knocked that down to just 3.7%, a 67% decrease! That means consumers will save over $138 million in 2022. Small group plans requested an average rate increase of 14%, which was reduced to 7.6%. That reduction will save small business owners over $468 million in 2022.

In the individual market the biggest reductions were for Healthfirst (from a requested increase of 34.4% to an approved increase of 9.7%) and Highmark Western and Northeastern NY (from a requested increase of 18.1% to an approved increase 6.2%. Three plans will lower their rates in 2022: IHBC by 4.4%, MetroPlus by 3.9%, and Fidelis (by 0.1%). These final rates are an average across all the individual plans offered by each carrier.

“Prior approval” means that insurers submit requests to state regulators explaining what they plan to charge next year. The Department’s job is keeping premiums as low as possible while making sure that plans stay solvent. The rate applications include information on the plans’ costs during the current year (though this year they used 2019 data because 2020 was such an outlier) and assumptions the plans have about costs next year. DFS looks at this data and especially at the assumptions plans make to see if they are in line with other sources. For example, the plans provide an estimate of medical trend. Medical trend is the change in what plans spend on health services for members each year due to changes in prices for those services and how often members receive health care. DFS frequently disallows trend estimates that are too high with no justification. DFS has also capped profit in the past to keep rates down. For example, last year it capped profit at 0.5% for all plans.

Prior approval in New York is a public process and members of the public are able to submit comments on the rate requests. You can read our comments on each plan’s request here. This year, many commenters talked about the financial difficulties they are experiencing because of the pandemic. Others talked about paying higher premiums every year but struggling to find doctors and receive care. Some asked why costs aren’t going down given cheaper ways of providing care like telemedicine or the new customers plans will get in 2022 because of the American Rescue Plan’s higher premium subsidies. You can find your individual market plan and the public’s comments on it at these links:

Insurers offering products in New York’s individual, small group, and Medicare Advantage markets submit applications to the Department of Financial Services (DFS) each year which describes how premiums will change and why. DFS (and HCFANY!) encourage consumers to respond to these requests by share their experiences with DFS. How affordable do you think your current plan is? What would happen if your premiums went up as much as your insurer asks for? You can read HCFANY’s guidance for how to comment here, and submit your comments to DFS here.

Insurers have requested an average increase of 11.2% for 2022 on the individual market, which is very high given that consumers are still navigating the economic and health-related repercussions of the COVID-19 pandemic; in addition, insurers will likely continue to benefit financially from depressed utilization and the increased use of telehealth as a result of the pandemic. In some cases insurers didn’t give enough information about why they think premiums should increase. This isn’t fair to the public.

In our comments, HCFANY discussed many reasons why DFS should consider reducing the rate requests, including both market-wide conditions and specific factors in each insurer’s application. Find your carrier in the list below to see what we had to say!