Unintended Consequences Of Exchange Rate Filings

Carriers have responded in somewhat of an unexpected way, a rather bullish approach which will have a favorable impact on health premiums.


For most states offering health care exchanges, rate filings were due by May 1, 2013. Each carrier hoping to operate within the exchange had to finalize their benefit offering and related rate filing. Some of the results are gradually emerging as regulators review the filings. Some have been rejected, some have been accepted and approved, some are going through various stages of review and revision. The interesting result of this process is finding out what rates will be and what costs carriers expect.

Prior to the actual submission process, multiple reports were issued prognosticating what rate levels might emerge. Some of these reports suggested that the anticipated morbidity levels (i.e., claim levels) for those enrolling in these programs would be higher than current individual benefit programs. This was logical to most — the hard part was the anticipation of what was a reasonable load in light of what other companies might assume and use in their pricing.

We learned of estimates ranging from a low of at or above 10% to a high approaching 45% - 50%. An important consideration is the nature of the current individual products offered in the marketplace (i.e., are they individually underwritten or were they guarantee issue). In those states where health plans and carriers were permitted to medically underwrite the product, the transition to a guarantee issue product will be greater than in those states where the product was already a guarantee issue product.

Early results from several states show that some major carriers assumed lower than expected morbidity factors, with other carriers attempting to withdraw their filings and resubmitting more competitive rates. We are not aware of any exchange where carriers decided to withdraw and raise rates.

The unintended consequence of this is very interesting. Rates will be lower than many experts predicted. The market pressures have been significant with companies trying to reduce their rates. Whether this is the result of competitive pressure or a knee-jerk reaction to stay in the market, it is unclear at this time what this will do to financial performance. Under health care reform, carriers are at risk to enroll individuals that have a higher health status and risk profile. These individuals were uninsured in the past and now are going to enroll in some program or be subject to financial penalties.

For those individuals who were skeptical about the cost effectiveness of health care reform, this will have an interesting impact on premium levels. For those who anticipated some cost reductions, it is unclear that they anticipated this type of response. It is our understanding that complete rate results will be released in the State of California later this week. It will be very interesting to see how different carriers developed their rates.

The bottom line is that carriers have responded in somewhat of an unexpected way, a rather bullish approach which will have a favorable impact on health premiums.

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