Remember our blog post about the rate review process? (If not, that’s okay, you can read it here). HCFANY spent the last month reading premium rate applications and writing up comments. We submitted 10 letters to the Department of Financial Services about plans in the individual on-exchange market. You can read each one here:

• Affinity (6.63% requested rate increase)
• Empire (14.5% requested rate increase)
• Excellus (12.8% requested rate increase)
• Fidelis (4.66% requested rate increase)
• Health Republic (14.36% requested rate increase)
• Healthfirst (12.89% requested rate increase)
• HIP/Emblem (13.2% requested rate increase)
• MVP (13.48% requested rate increase)
• Oscar (4.54% requested rate increase)
• United (22% requested rate increase)

At the beginning of each letter, HCFANY describes six issues that apply to almost all the carriers in New York seeking rate increase. HCFANY urges the Department of Financial Services to keep these six issues in mind. First, the 2016 risk pool is likely to be the healthiest yet because the sickest consumers are typically the first to join and the ACA tax penalty for a consumer going without uninsurance is increasing. We argued that administrative costs and medical trend costs should be decreasing in the coming year. We discussed Medical Loss Ratio requirements as a floor, not a goal. Finally, we indicated that a number of the carriers’ filings provided very little detail in their supporting documents and urged the Department to establish stronger standards for carrier submissions.

Thank you to everyone who submitted their own comments to the Department of Financial Services and made their voice heard!