Rate Review Comments are Due Soon – Check Out Ours!

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)

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. While insurers are asking for smaller increases than we’ve seen in previous years (on average an 8.4 percent increase), that’s still too much for consumers to manage.

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!

In a recent blog post, we explained how New Yorkers can comment on the rates their insurers have requested for 2019. You can read that blog post here. The deadline for submitting comments is Sunday, July 1 so there isn’t very much time left.

Comments can be submitted electronically here. And you can find our letters for each individual carrier below. HCFANY submits very detailed comments – yours do not have to include the technical analysis you see in our letters. It’s important for consumers to speak frankly about how premium increases affect their households. Maybe you have to decide between health insurance and other necessities. Maybe you are considering not buying insurance. Maybe your insurer keeps giving you fewer choices of doctors even as you keep paying more. All of these issues need to be discussed publicly in New York.

This year HCFANY  asked the Department of Financial Services (DFS), which is responsible for regulating insurance and reviewing the rate applications, to help convene a workgroup to talk about strategies the state can use to control premiums. The rate review process allows DFS to reduce premium requests every year, but more needs to be done.

Comments on all 12 of the carriers who applied for the individual market are below: