Here’s How to Comment on Insurers’ Rate Increase Requests

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 5.

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 11.7 percent this year. The average requested increase was 11.4 percent in the small group market. Insurers attribute an average of 3.1 percent of the increases to the impact of the COVID-19 pandemic. Some plans cite COVID-related testing and treatment, increase in hospital costs, and the possibility of a vaccine next year as reasons to approve rate increases. It is also important to note that this year health care utilization dropped as consumers cancelled and postponed doctor’s visits and non-urgent surgeries because of the pandemic, while insurers continued to collect premiums.

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 decreased insurers’ requested rate for individual coverage from 9.2 percent to 6.8 percent, which saved consumers over $50 million. It also reduced rates for small group coverage from 12.2 percent to 7.9 percent, a 35% decrease that saved small businesses over $313 million.

HCFANY submits detailed comments every year – you can see the types of arguments we make in our letters from 2019 (link) and 2018 (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 Health Plan: Narrative Summary (link), Complete Application (link)
  • Excellus: Narrative Summary (link), Complete Application (link)
  • Fidelis (NYHQC): Narrative Summary (link), Complete Application (link)
  • Healthfirst PHSP: Narrative Summary (link), Complete Application (link)
  • HealthNow: Narrative Summary (link), Complete Application (link)
  • HealthPlus Empire: Narrative Summary (link), Complete Application (link)
  • HIP/Emblem: 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)

Call 1-888-614-5400 for enrollment help!

The New York State Department of Health has announced a special enrollment period in response to the spread of COVID-19. That means if you are uninsured, you have special permission to buy health insurance through the NY State of Health Marketplace (https://nystateofhealth.ny.gov/). This special enrollment period ends April 15 – so don’t wait!

What does this mean? Open enrollment periods exist to discourage people from waiting until they know they have big bills coming to buy insurance. If everyone did that, health insurance would quickly become unaffordable to almost everyone. During open enrollment, people have to decide – can I afford health insurance? And does it make sense to me to buy health insurance given my usual health expenses? Some people gamble that they won’t have any serious health problems during the year and chose not to enroll. But once open enrollment ends, those people cannot decide to buy insurance if say, they need an x-ray or were exposed to COVID-19 at work. There are always special enrollment periods for big life changes – for example, becoming pregnant or losing a job.

Open enrollment for 2020 ended on February 7 in New York. Two months later, during a public health emergency, there may be some uninsured people who feel differently about their decision. This announcement means you can turn back the clock and get insurance! Are you worried about costs? Navigators and other assistors are working throughout the emergency to help you! For enrollment questions, dial 1-888-614-5400 and choose option 1, and then 1 again.

Other things to remember:

  • Any plan you enroll in through the State, including a private plan you buy through the NY State of Health, is required to cover COVID-19 testing without cost-sharing.
  • You can enroll in Medicaid, the Essential Plan, or Child Health Plus at any time of the year based on your income. Enrollment uses the same NY State of Health application that you fill out to buy health insurance.
  • If you have lost your job or experienced a decline in pay, talk to an assistor about it. You might be eligible for premium subsidies or programs that you weren’t eligible for during open enrollment.

This is a fluid and scary situation. Obtaining health insurance is one step New Yorkers can take to prepare for the next few weeks.



The new 2018 census data numbers are out this this morning. 

The bad news is that uninsurance numbers increased across the country by 1.9 million in 2018, despite the positive economy. This was the first increase in uninsured since the Affordable Care Act was fully implemented in 2014. Here’s a New York Times article with more details.

BUT, there’s great news in New York, which was one of just three states in the country to have a decline in our uninsurance numbers, from 1,113,000 in 2017 to 1,041,000 in 2018 (our uninsurance rate declined from 5.7% to 5.4%). 

New York’s continued decline in uninsured residents is inextricably linked to its adoption of the high quality, affordable, Essential Plan, which saw an increase in enrollment from 665,000 in 2017 to 739,000 in 2018.  Other important factors include:

  • One-stop shopping: you can apply for the full spectrum of coverage, including Medicaid, Emergency Medicaid, Child Health Plus, the Essential Plan, Qualified Health Plans and tax credits, all through the same NY State of Health application
  • Robust Navigator funding of $27 million a year

Congratulations New Yorkers! And let’s keep up the good work!

Health insurers in New York are asking for rate increases again this year: in the individual market an average of 8.4 percent and in the small group market, an average of 12 percent. UnitedHealthcare of New York asked for the biggest increase in the individual market (27.1 percent), while HealthPlus (Empire) asked for the smallest (2.4 percent).

In New York, insurance premium changes in the individual, small group, and Medicare Advantage markets are subject to prior approval. That means the state has to review their justifications and decide if they are asking for a reasonable change. The data provided to the Department of Financial Services, which regulates health insurance in New York, are available publicly and the public is able to post their own comments. HCFANY submits comments each year assessing whether or not the carriers are asking for reasonable changes. If not, we ask the Department of Financial Services to reject their requests. You can see the letters we wrote last year here. DFS wants to hear from you, too! You can find a guide for submitting your own comments here. The comments are due by June 28 – you can find your insurance company’s application here.

The requests are much smaller this year in the individual market than they were last year. This reflects the success insurers had in 2018. Nationally, this was the most successful year yet for the individual insurance marketplaces created by the Affordable Care Act (ACA).[1] The ACA remains in place despite federal efforts to sabotage the law – and states like New York have worked hard to counteract that sabotage, which creates a more stable environment for insurers.

One sign of this success is that insurance companies owe customers about $800 million in rebates because their medical costs were so much lower than the premiums they collected. The ACA requires them to spend at least 80 percent of their income on medical services – instead, they only spent 70 percent. The average medical loss ratio for the major carriers applying in New York was 85.4 percent, just above the state’s minimum of 82 percent. Four New York carriers failed to meet the state threshold.

Even though the request is smaller than past requests, it is hard for consumers to manage any premium increase. New Yorkers increasingly report that they cannot afford health care, even when they buy insurance. Many New Yorkers get assistance with insurance premiums through the Affordable Care Act and so won’t be affected – but those that don’t get assistance cannot manage another increase. Your voice matters in New York – while the Department’s decisions must be based on the information provided by the insurers, your stories about managing (or not managing) premium increases over the past few years add valuable information to public discussions about health care in New York. New York will only develop good solutions to our affordability crisis by listening to all voices – we need to hear from you!


[1] Cynthia Cox, Rachel Fehr, and Larry Levitt, “Individual Insurance Market Performance in 2018,” Kaiser Family Foundation, May 7, 2019, https://www.kff.org/private-insurance/issue-brief/individual-insurance-market-performance-in-2018