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

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!

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)