Insurance Department asks for Feedback and PPF Responds

January 29th was the date of the last PA Insurance Department’s e-newsletter. The newsletter contained an article with the following headline: “Insurance Department Issues Guidelines for 2017 Health Insurance Rate Filings”. The guidelines can be found here.

What are these “guidelines” and what do they mean?

The newsletter goes on to say this:

“Commissioner Miller has made transparency a top priority for the department and believes transparency needs to work both ways. The department is striving to be more transparent with the industry about its priorities and processes, while at the same time trying to make more information about its insurance markets available to the public and understandable for consumers. To help achieve these goals, the department has posted on its website draft guidance that proposes requirements for information issuers must submit in their 2017 ACA-compliant individual and small group health insurance rate filings. The department’s goal with this guidance is to make sure the initial rate filings contain the information the department needs to evaluate fully the proposed rate changes and that the information is presented in a clear and consistent manner. The guidance will also outline and standardize what information contained in the rate filing the department intends to make public, when it will be made public, and how it will be presented to consumers.”

In other words, the “guidelines” lay out 1) what information insurance companies have to submit to the PA Insurance Department when they request premium increases for 2017 on the Affordable Care Act Marketplace 2) what information will be made public for healthcare consumers and how it will be made available.

At PPF, we believe that before any decisions are made to increase health insurance premiums on ACA plans, there should be public hearings for the Insurance Department to share information on the proposed increases and to hear from individuals and families about how these increases might impact them. Currently, the guidance does not include public hearings as part of the process.

In addition, the Insurance Department asked for feedback by February 5th, giving a comment window of only one week on a process that stands to impact hundreds of thousands of people across PA – this year 150,000 people were impacted by plans that saw premium increases across the Commonwealth.

Below is our response to the request for feedback. Please read it and join today if you’d like to help we ensure that PA Insurance Department is accountable and transparent to us and that public hearings are held before any additional rate increases are approved.

 

Here is PPF’s response to the request for feedback:

We shared the draft rate filing guidance with our membership and had the following comments:

Thank you for asking for public comment on the guidance, although the window of time was quite short, and the guidance is not presented in language that everyday people can understand, leading us to believe that it was not intended for healthcare consumers.

One of the biggest recommendations we have for changes to the guidance is thatpublic hearings are necessary to inform consumers about proposed rate hikes and hear how such hikes might impact them before decisions can responsibly be made by the Insurance Department. Otherwise what we have is a completely one-sided process which privileges major corporations over individuals and families throughout the Commonwealth.

Additionally we make the following recommendations:

1) Require written and publicly available decisions on rate cases.

2) Require a justification of overhead.

3) Include consumer representation.

4) Calculate rate hikes based on modes instead of averages.

5) Factor in fundamental trends of changing utilizations based on preventative and chronic care when using past experience.

6) Require cost containment/savings and improving preventative medicine.

We would like to set up a meeting with your office to discussion these recommendations further.

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