Rate Actions Taken by New York’s Department of Financial Services Will Save New Yorkers $607 Million in 2022

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!

Premium requests made by New York’s insurance companies have been posted, and consumers have the chance to share their thoughts on these requests! New York State requires this approval for all individual market, small group, and Medicare Advantage plans. If your plan is part of this process, you should have received a letter from your insurer explaining what they requested and how you can submit comments to the state’s Department of Financial Services (DFS). The insurers’ applications are available through DFS’s website and are linked below. Public comments are due in late June and can be submitted online here.

It is important to remember that at this point, these are only requested changes; DFS will review insurers’ applications along with consumers’ comments when determining the approved rates for 2022. Last year, DFS decreased insurers’ requested rate for individual coverage from a 11.7 percent increase to a 1.8 percent increase, the lowest rate increase ever approved. The changes saved consumers over $221 million. DFS also reduced rates requests for small group coverage from 11.4 percent to 4.2 percent, a 63 percent decrease that saved small businesses over $565 million.

This year, the average request was 11.2 percent in the individual market. Healthfirst PHSP, Inc. requested the highest increase at 34.4 percent. The plan cites higher provider charges in its new service areas in Westchester and Rockland counties for most of this increase. Six other plans requested double digit increases: Highmark (18.1 percent), MVP (16.9 percent), Unitedhealthcare (13.9 percent), Oscar (13.6 percent), CDPHP (11.4 percent), and HealthPlus (10.2 percent). MetroPlus (-3.9%) and Independent Health Benefits Corporation (-.2%) each requested decreases. For small group plans, the average requested increase was 14 percent, ranging from a 17.6% requested increase by Highmark Western and Northeastern New York (formerly Healthnow) to a 4.5% requested decrease by Aetna Health.

HCFANY submits detailed comments each year, which you can see in our letters from 2020 (link) and 2019 (link). Consumers do not need to provide this much detail; if you do comment publicly, you can speak about how the proposed changes to your plan would impact you. For example, what changes would you have to make if your insurance company were allowed to increase their rates? Would you still buy insurance? HCFANY has longer instructions available (link), but the most important thing is to use your own experience.

Individual Market Applications

We’ve compiled the links to applications for each insurance carrier that participates in New York’s individual market through our health insurance exchange below. We’ve included both the narrative summaries, which are shorter (under 10 page) explanations for the requested rate changes, as well as the complete application links for those who wish to review the applications in greater detail.

  • CDPHP Health Plan: Narrative Summary (link), Complete Application (link)
  • Emblem (HIP): 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)
  • Highmark Western and Northeastern New York (Formerly HealthNow): Narrative Summary (link), Complete Application (link)
  • HealthPlus Empire: Narrative Summary (link), Complete Application (link)
  • Independent Health Benefits Corporation: 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)

Each year, the Department of Financial Services reviews applications from insurers in the individual, small group, and Medicare Advantage markets and decides whether rates should go up, down, or stay the same. This year, insurers are asking for an average increase of 11.7% in the individual market, which is too much for consumers to manage especially in the midst of the economic and health-related repercussions of the COVID-19 pandemic. Submit your comments here by July 5.

HCFANY found plenty of reasons in the individual market filings to reduce or even reverse those increase requests. Find your carrier in the list below to see what we had to say!