MVP Health Plan, Inc.Individual2019 Public Comments

Hi my name is and I for a living and have to pay for my own health insurance co pay's deductible's and so forth on my own. Its got to the point to where I just cant afford good insurance and being I need it. Why do the prices have to keep going up so high every year. My health insurance is now more than what I pay for my mortgage 20.00 more to be exact. It seems like there has to be something done to stop these cost going so high. I do use my insurance but then I get hit hard with co pay's and deductible's. I'm going broke and feel like I'm sinking these day's. I guess I just don't understand why? Does it really have to keep going up every year? I'm only so I have many years of work left and may not be able to retire do to seriously running out of money. People think all are rich and that's just not the case some are barley getting by and I'm getting to that point. This madness of health insurance has to stop or people are just going to stop going to doctors till their on death's bed. So very concerned for my future.

I have been paying for my own health insurance since my husband retired two years ago. His COBRA insurance was way too expensive. I am self-employed. The rate increase proposed by MVP is ridiculous. Last year it increased so I chose a cheaper plan. Now they want to increase it 14.27 percent for the year 2019. I CANNOT AFFORD THIS. I will switch carriers if need be. Plus they tried overcharging me when I switched within their plans when the rate increased after my first year. They kept charging me for the old other plan. I had to correct them on the amount numerous times. My field of employment is such that I could virtually do it anywhere in the USA. Maybe my husband and I should think of relocating. NYS INSURANCE IS TOO EXPENSIVE. It is not fair to those of us in business versus those who are protected by unions etc to pay far more for the less coverage. Shame on MVP for increasing rate yet another year.

I am currently enrolled in an MVP Health Care plan, Non-Standard Gold 5, with individual coverage. I am a retiree, non Medicare eligible. My former company was providing healthcare until January 2017. The first of paying out of pocket, cost me $614/mo. January 2018 it jumped to $691/mo., 12.5% increase, and next year is a proposed rate hike of %17.31, bringing the cost to $810/mo. This is for a plan with a $1200 deductible, $4700 annual out of pocket max, copays, coinsurance, etc. In a word, lousy coverage, with exorbitant rates! This is unconscionable! Something has to be done before more residents, like myself, vacate New York State, and move somewhere where we can afford to live! Thank you, for your time.

I think it is absurd that a premium increase of 19% imposed on persons who are off market place subscribers and also allow open ended backdoor changes to co-pay, coinsurance or possible out of pocket changes not reflected in the premium increase. I chose to go off market place because when all the Democrats had their pockets wide open during the closed door process of Affordable Care Act I did not want to be a part of that but it now seems that I cannot avoid paying for those to get health care that have little or no record-able imcome

MVP Health Plan, Inc.Individual2019 Public Comments

My husband and I have to purchase our insurance entirely out of pocket. Our current 2017 premium is $1750 per month. This was increased from $1500 in 2016. An increase in 2019 of 18.98% will put our premium at $2080 per month or almost $25000.00 per year! This has to stop. We are only yrs old. I am retired after nearly 40 yrs of work but my husband who would like to retire after a 40 yr career can't mostly because of our medical ins. We worked in the private sector. The companies we worked for pulled back on health care and no longer offer it.

I strongly oppose a rate increase. Every year my rates increase, while my pay stays the same. At the same time, due to the increase I am forced to change my plan to a selection with a higher deductible. The cost is so high I am at the point where I can no longer afford insurance for my family. I pay full price because I work two jobs and make to much. How about the executives in the company skip the bonus and pay increase this year. The insurance industry is broken and cares nothing about the people who support it.

My insurance is for my daughter and myself. We have a fixed income. To absorb an 11.73% increase means another $150 per month. This is not an expense that can be absorbed. There is no where else to cut expenses. We try to keep ourselves healthy, eat right, exercise, no smoking or alcohol. For the insurer to base its increases on enhancements to medical technology and changes in federal tax system as part of its justification are not solid reasons. Changes such as these need to be dealt with and absorbed through their internal processes. We as consumers can't be expected to absorb all economic changes. They need to look at their expense structure, especially administrative, and make appropriate adjustments to avoid passing on to the consumer. Health care organizations go through this annually with cutbacks in medicaid and medicare reimbursements and adjust their cost structures accordingly in order to survive. MVP needs to do the same. Thy need to be taken to task on this. There are many of us who are in the same situation. We have been absorbing these double digit inceases for years and have been cutting back expenses and getting second jobs. We can't cut back any further or work any harder. This request should be denied. The consumer who is trying to do everything right needs HELP, please! Don 't let us feel like we have no advocate.

My health insurance plan has increased by over 10% each year for the past 5 years......My income has not increased by that much over the last 5 years.....Individual health insurance is getting out of control..........Health insurance now cost MORE than a home mortage....We need relief...!

The proposed premium rate increase of 20.77% for 2019 by MVP seems extreme! I've never heard of such a radical jump in premium. I hope this will not be approved.

MVP Health Plan, Inc.Individual2019 Public Comments

The increase of health insurance and of healthcare itself is killing people daily. The wickedness that it takes to tell someone that their life isn't worth saving because of their financial status is staggering. Every cent that it rises means less access for the people who need it most. Health insurance costs should be going DOWN. The culture of the healthcare industry is parasitic - cancerous even, as the unrestricted growth has at best crippled the nation's growth. If you had people's interests at heart, you would be making access easier to afford, or even free! What a concept, keeping people alive and healthy being a goal of health care industry! Well a girl can dream right? And a person can speak truth to power (for the time being) right? My words matter right? My life is important yeah? Or is it just my business that you're concerned with? I'm quite disheartened that MVP would try to squeeze more out of it's customers, but not surprised. Please don't increase any rates. I already almost can't afford my job as it is. Yes, I typed that correctly, that with the health insurance I am forced to purchase, it makes my job close to $0 profit. And insurance costs are a huge part of that. So again, please, don't increase a rate, we should be moving to universal healthcare, not tightening the screws of a damaging system. Blessings to you, person, and your family.

This Is ridiculous!!!! I am retired with a FIXED income not on Medicaid or Medicare. My health insurance premiums have gone from $88 per mon. 3 yrs. ago to $188 per mon. 2 yrs. ago to $288 a mon. this year and now MVP wants another 13.42% for next yr. I have friends who can not pay their property taxes because of their health care premiums. I have lost 47 lbs. over the past 2 yrs., am on an exercise plan and take yoga classes. My Dr. has taken me off meds. I am in the best health I have been in the last 40 yrs. Yet my health insurance costs are going crazy. Does the state legislatures ever tell these people ENOUGH!!?? The insurance companies CEO's will still go home with their million dollar bonus checks regardless. If the tax payers have to decide on staying in their homes or paying absorbent insurance costs then the numbers of uninsured will never go down!

I retired March 1st, only income is social security and a small 401k. I worked 42 years as an I believe that 300 plus million dollars for the CEO of Mvp and close to 300, 000 for each VP is enough. Please don't allow them to once again raise our premiums!

This is an appeal for you to NOT increase MVP Health Care insurance premiums for 2019. Health care costs are out of control. Personally, I was laid off from my full time job 5 years ago and since then, I've been doing freelance work to make money. I'm in the over category, one that is not seen as desirable by most companies. It's a struggle to make ends meet. Insurance already takes a sizeable chunk out of my monthly income. There are many, many like me in the same position. Insurance costs continue to rise substantially every year, but one of the biggest reasons why is because doctors charge insurance companies extortionate costs for patient services. I've seen examples of charges that are absolutely eye-popping! Maybe we need to change the rules of the game: stop paying out huge sums to greedy doctors and maybe -- just maybe -- insurance premiums remain within a reasonable range for the people. Please do NOT approve MVP's premium increase for 2019. Do the right thing.

MVP Health Plan, Inc.Individual2019 Public Comments

I just want to share that I cannot afford a 20.77% increase in my premium. A 5% increase is more than I can afford but 20.77% is just unrealistic. I have been very fortunate to not have to use my insurance but according to the letter from MVP, others have must have used theirs excessively and I am getting penalized in my costs. Whatever you can do to prevent this excessive increase would be greatly appreciated. If I didn't have a job, I would get health care for free. What kind of message does that send?! Thank you in advance for your time and consideration.

I have been faced with the annual increases in the MVP premiums. I have lowered coverage and increased deductibles each time. I am now faced with the fact that the premiums are now going beyond my reach. I earn too much to qualify for help, but not enough to meet the new increases. Sincerely,

Good Morning, Once again as summer approaches after being on MVP for ONLY 6 MONTHS I received a rate increase request. Just unbelievable! How are people to live with these sky high premiums? As it is I am paying close to 800 dollars per month for individual coverage. I just don't understand what has happened to the healthcare system. My husband lost his job and between the 2 of us we are paying 1500 per month for insurance. His is through Cobra. Please take into consideration that a 11.86 increase will be another 94 dollars per month. It seems as though you have to make a choice between food or health insurance. Just heartbreaking that it has come to this. Hopefully you will read this and take it into consideration when making your decision. Thank you for your time and letting me vent.

We live in upstate NY, a small town called and decided to help preserve a community and open a small business. Since leaving corporate, we've had to take out insurance via the plan for individuals and your proposed rate increase of almost 18% is ludicrous! We can see a small % increase year over year but 18%??!! You make it impossible to afford health insurance and do not offer the small businesses any advantages like you do large corporations. We are extremely disappointed and switched from BBBS to MVP Standard Gold as a way to save $. We even opted for the one with a $600 per individual deductible as a way to cut down on expenses and pay out of pocket ourselves since we do not routinely go to the doctors or have any long term health issues. We will definitely be shopping our health care coverage again and would appreciate a response on why you feel it's necessary to increase at such a dramatic rate.....!

Unknown Insurer2019 Public Comments

-----Original Message----- From: Insurance Inquiry Sent: Friday, June 08, 2018 9:42 AM To: Subject: NYS Department of Financial Services Consumer Assistance Unit Inquiry : Your inquiry submitted to the NYS Department of Financial Services Consumer Assistance Unit has been received and will be reviewed promptly. The information you entered is as follows: Your Name: Email:

Your Company/Organization: Daytime Telephone#: You are a(n): CONSUMER Type of Insurance question/comment: HEALTH Your Questions and/or Comments have been recorded as follows: * * * * * * * * * * * * * * * * * * * * * * * * * Why do health insurance costs go up every year without fail? And why do you use obfuscating language in your increase notice. "Modify"! "Change"! oh please! This is a shameful racket and anyone- anyone who plays a part in it should be ashamed of themselves. Wake up and be human! * * * * * * * * * * * * * * * * * * * * * * * * * Sincerely, New York State Department of Financial Services Consumer Assistance Unit. email at: consumers@dfs.ny.gov

MVP Health Plan, Inc.Individual2019 Public Comments

I think it to be absolutely ridiculous that Insurance is mandated by government only to have these companies to continued increase. My average cost has more than doubled since all these new laws. Im gonna make sure that every American has affordable health care. Yes he did, and we are gonna pay for those whom cant.... Insurance is a business. It gambles on loss and gain to bank away its bottom line. Cut costs inter company not increase receivables from people whom are STILL WILLING to pay. At this point I'm starting to wonder if the penalty is more than $8,837.51 I would have to pay next year should said increase be granted. I also wonder if every Tax payer, Personal Insured person in the state and country chose not to pay because of disgust in increase. Who will pay for those that DONT PUT INTO THE SYSTEM.

I am a sole proprietor with no employees, my monthly premium is $552.69 with MVP. The increase will put me over $610 a month.That is over $7300 annually and I'm fairly healthy at . After taxes and health insurance I'm supposed to live on $10k annually?? Good thing my wife has a good job, but these health insurance premiums are killing us.

MVP does NOT deserve an increase. They get an increase EVERY year and decrease benefits every year. This year when I got sick, hit roadblocks at every corner.

As a Non-Profit organization that is grant funded, our employees handle highly confidential sensitive information in the services. Due to the amount of work that is provided and the low salary it is imperative to

not increase premium cost for our employees. We appreciate any assistance due to this. Thank you!

Every year there are increase requests by insurance companies making seemingly yearly record breaking profits. Last year and the increase approved for MVP was considerably higher than this year to the tune of $300+/month to my simple policy with three people in a household. Meantime, what they provided was decreased and obtaining approval and finding a doctor even harder than ever. These requests are always more than the, if possible to get, standard rate of living increases one may hope to get. If every company were to do/request the same, no one could afford to do business or obtain services from anywhere. On top of increases, benefits are decreased for what we pay more and more for. Something has to be done for the individuals more and less for big businesses making tremendous profits while providing less and less services and less and less quality/care.

Actors Fund African Services Committee Children’s Defense Fund-New York

Community Service Society of New York Consumers Union Empire Justice Center Make the Road New York Medicare Rights Center Metro New York Health Care for All Campaign New Yorkers for Accessible Health Coverage New York Immigration Coalition Project CHARGE

Public Policy and Education Fund of New York/Citizen Action of New York Raising Women’s Voices-New York Schuyler Center for Analysis and Advocacy Small Business Majority

Young Invincibles

Health Care For All New York c/o Amanda Dunker, Community Service Society of New York

633 Third Ave., 10th Floor, New York, New York 10017 (212) 614-5312

June 28, 2018 Maria T. Vullo, Superintendent Troy Oechsner, Deputy Superintendent for Health John Powell, Assistant Deputy Superintendent for Health NYS Department of Financial Services One Commerce Plaza Albany, NY 12257 RE: Requested Rate Changes – MVP– Individual – 131481104 Dear Superintendent Vullo, Deputy Superintendent Oechsner, and Assistant Deputy Superintendent Powell:

Health Care for All New York (HCFANY) is a statewide coalition of over 170 organizations dedicated to achieving quality, affordable health coverage for all New Yorkers. HCFANY believes that the public rate review process is a vital consumer protection and is grateful for the opportunity to submit comments on the rate requests submitted for 2019’s individual plans. The comments below address concerns about the market as a whole before offering specific comments on MVP.

I. Market-Wide Comments

A. Action is needed beyond the rate review process to stabilize New York’s individual market.

HCFANY is concerned that New York’s insurance companies have not successfully

controlled costs in the individual market. This year, the carriers seek an average 24 percent rate increase for the 2019 individual market plans.1 This is the fifth year in a row that the requests have been in the double-digits for the individual market (the previous four years of requests and approved rate changes can be seen in the chart below).

1 New York State Department of Financial Services, “Proposed 2019 Health Insurance Premium Rates for Individual and Small Group Markets,” June 1, 2018, https://www.dfs.ny.gov/about/press/pr1806011.htm.

www.hcfany.org Health Care For All New York Page 2

Average Requested and Approved Premium Increases New York’s Individual Market 2015-20182

Request (Percent) Approved (Percent) Percent Change 2018 17.7 14.5 -18.1 2017 19.3 16.6 -13.9 2016 10.4 7.09 -31.8 2015 12.5 5.7 -54.4

Such large increases cause immense hardships for those New Yorkers who receive little

or no financial assistance through the NY State of Health Marketplace. Fortunately, most people (59 percent) in the Marketplace do receive help through tax credits that are based on income and grow as prices increase.3 As a result, many are insulated from rate increases. However, 41 percent of people who enrolled in qualified health plans last year received no assistance.4 That means they bear the full brunt of any approved premium increases. HCFANY is concerned that approving rate increases so far above the rate of medical inflation will eventually result in enrollment declines and ultimately, an insurance “death spiral” that would catapult premiums beyond the reach of anyone ineligible for assistance.

HCFANY commends the Department for its past efforts to safeguard consumers by reducing the carriers’ average rate increases substantially and urges it to do so again this year. HCFANY’s recommendations for doing so, based on a close reading of the applications, are below. HCFANY additionally asks that the Department and other state leaders take more forceful action outside of the rate review process to stabilize the individual market. High premiums force New Yorkers to choose between healthcare and necessities like housing and food.5 Those choices continue even after someone gains coverage as they make their monthly payments and then face increasing cost-sharing.6 High premiums also contribute to disparities in well-being between white Americans and others. Adults who are black are much more likely to report an inability to afford basic necessities and health care than adults who are white.7 Adults who are black or Hispanic are more likely to have had medical bills turned over to debt collectors than those who are white.8

2 For 2018, see https://www.dfs.ny.gov/about/press/pr1708151.htm. For 2017, see https://www.dfs.ny.gov/about/press/pr1608051.htm. For 2016, see https://www.dfs.ny.gov/about/press/pr1507311.htm. For 2015, see https://www.dfs.ny.gov/about/press/pr1409041.htm. 3 New York State of Health, 2018 Open Enrollment Report, May 2018, page 5, https://info.nystateofhealth.ny.gov/sites/default/files/NYSOH%202018%20Open%20Enrollment%20Report_0.pdf. 4 Ibid. 5 NORC and the West Health Institute, “Americans’ Views of Healthcare Costs, Coverage, and Policy,” March 2018, page 2, http://s8637.pcdn.co/wp-content/uploads/2018/03/WHI-Healthcare-Costs-Coverage-and-Policy-Issue-Brief.pdf. 6 NORC and the West Health Institute, page 8. 7 Ibid. 8 NORC and the West Health Institute, page 6.

www.hcfany.org Health Care For All New York Page 3

The role of private insurance companies is to pool risk for large numbers of enrollees and negotiate and control prices on their behalves. This year, as in the past, the carriers’ applications state that providers are so powerful that this process cannot take place. If this is true, New York should take steps to control prices in the individual market and ensure that people who purchase their own plans have affordable coverage options. Other states have been more successful in keeping prices down in the individual market. For example, Minnesota has implemented a reinsurance program that has resulted in substantial declines in its individual market rates (between 3 and 12 percent).9 To control prices in the individual market, New York should consider the following strategies:

1. Provide premium assistance to people who make above 200 percent of the federal

poverty level. Increased premium assistance would stabilize prices by increasing the size of the risk pool. The more enrollees insurers have, the more they can spread the costs of care across individuals. Ideally, premium assistance would be available to everyone based on income. Encouraging greater participation by some groups could particularly help stabilize the individual market without great cost.,. Young people, for example, have lower incomes and lower health risks than older people. This means they are more likely to gamble against buying health insurance when dealing with tight budgets. Providing assistance to them would attract more people into our individual market who are lower risk. Insurers would be able to lower costs benefitting many in the market, and young people would have financial security in the event of a health emergency.

2. Create a drug utilization review board for commercial plans in the individual market

similar to the review board that exists for Medicaid. All of the carriers cite increasing pharmacy prices as a reason for premium increases. For example, HealthNow estimated that medical prices would only increase by 3 percent while pharmacy prices would increase by 9.5 percent. Since so many insurance companies report being outmatched by the pharmaceutical industry, the state should consider intervening. New York’s Medicaid program has a Drug Utilization Review Board charged with reviewing clinical information and making recommendations to the Commissioner of Health on drug coverage.10 The Board’s meetings are public, it includes consumers, and the process for nominating members is transparent. Such a Board could ensure that consumers benefit from any rebates and could negotiate for lower pharmacy costs across the market.

3. Consider a public option such as an Essential Plan Buy-In Program. The state should

allow more people to participate in the Essential Plan as an affordable alternative to the individual market. The Essential Plan provides comprehensive coverage to people who earn between 138 and 200 percent of the federal poverty level.11 Participants at the highest

9 Minnesota Commerce Department, “Health insurers propose decreased average rates for Minnesota’s 2019 individual market,” June 15, 2018, https://mn.gov/commerce/media/news/?id=342571 . 10 New York Department of Health, Office of Health Insurance Programs, “Medicaid Drug Utilization Review Board General Operating Procedures,” https://www.health.ny.gov/health_care/medicaid/program/dur/docs/operating_procedures.pdf. 11 Empire Center, “A surprising surplus in Albany,” February 14, 2018, https://www.empirecenter.org/publications/a-surprising-surplus-in-albany/.

www.hcfany.org Health Care For All New York Page 4

income level pay only $20 a month; the cost of their care to the state is minimal because most funding comes from the federal government.12 New York could allow people with higher incomes to participate in the Essential Plan and offer state subsidies on a sliding scale. At a minimum the state could allow people to pay full-price to participate in the Essential Plan.

Other states have adopted additional measures that may be worth considering, such as the

state-based individual coverage mandates recently adopted by New Jersey and Vermont.13 Massachusetts has also had an individual mandate in place since 2006.14 Alternately, New York could seek a 1332 Waiver to establish a reinsurance program along the lines of Minnesota or Alaska.15 Finally, New York should seriously consider stepping in for the plans and controlling costs more directly through a Maryland-style global payment model.16 All of these ideas—and more—bear scrutiny in the face of the carriers’ substantial and persistent rate requests and HCFANY urges the Department to establish an Advisory Commission to explore them.

B. Within the rate review process, there are several areas in which we respectfully ask

DFS to question insurers’ arguments and impose greater standardization in their requests.

It is evident that federal activity has had a modest impact on New York’s individual

market. However, New York State has taken important steps to protect companies from those actions. Those steps included increasing the budget for enrollment assistors in the 2019 budget and opting to maintain the three-month open enrollment period. Additionally, under New York’s strict laws, the carriers face little threat from the federal liberalization of rules governing association health plans.

As a result of the state’s actions and an improved economy, New York’s individual

market appears to be stable—not contracting as some carriers claim. The New York State of Heath boasted an overall increase of 4 percent in 2018 enrollment.17 Although New York’s individual off-exchange marketplace lost enrollment, that appears mostly to be a self-inflicted wound imposed by the actions of one carrier (Empire) which terminated its entire line of

12 Ibid. 13 Katie Jennings, “New Jersey will become second state to enact individual health insurance mandate,” Politico New Jersey, May 30, 2018, https://www.politico.com/states/new-jersey/story/2018/05/30/new-jersey-becomes-second-state-to-adopt-individual-health-insurance-mandate-442183. 14 Ibid. 15 Cheryl Fish-Parcham, “Alaska’s Reinsurance 1332 Waiver: An Approach that Can Work, Families USA, August 2017, http://familiesusa.org/product/alaska-reinsurance-1332-waiver-approach-can-work and 2017 Minnesota Session Laws, Chapter 13—H.F.No.5, https://www.revisor.mn.gov/laws/?year=2017&type=0&doctype=Chapter&id=13. 16 Shah et al., “Maryland’s Global Budget Program: Still an Option for Containing Costs,” The Commonwealth Fund, April 3, 2018, https://www.commonwealthfund.org/blog/2018/marylands-global-budget-program-still-option-containing-costs. 17 Burton et al., “What Explains 2018’s Marketplace Enrollment Rates?,” Robert Wood Johnson Foundation, June 2018, https://www.urban.org/research/publication/what-explains-2018s-marketplace-enrollment-rates.

www.hcfany.org Health Care For All New York Page 5

individual market products, causing disruption and panic amongst its 50,000 members.18 In addition, more New Yorkers may be securing job-based coverage as the economy has improved. Despite these two trends, with a few minor exceptions, nearly all the other plans gained members between 2017 and 2018.

These conditions may not be adequately reflected in the 2019 rate requests. Thus,

HCFANY urges the Department to carefully review the carriers’ filings in a manner that ensures consistency of rate actions in the following areas: (1) the individual mandate; (2) trend; and (3) administration costs.

1. Increases due to the loss of the mandate should be reasonable and companies with

similar risk profiles should receive similar increases. In 2019, the federal tax penalty for failure to purchase health insurance will be

eliminated. The carriers’ applications contained varied estimates of the impact of this change with adjustments ranging from 0 percent to 23 percent. It is plausible that the variation of estimates is due to a carrier’s claims experience and premium levels (which make the plan more or less likely to be attractive to someone on the fence about buying a plan). However, this explanation for the diversity of estimates is belied by the fact that carriers with apparently similar risk profiles are asking for vastly different increases. For example, Oscar and Fidelis have similar average claims costs, yet Fidelis asks for a 23 percent increase to make up for losing the mandate while Oscar asks for just 7 percent.

To ensure that all New Yorkers in the individual market are treated fairly and equitably,

the Department should consider imposing a cap on the individual adjustment mandate—such as six percent, which is the average across all carriers. Those carriers that filed adjustments below six percent should be granted the adjustments that they seek (e.g. zero to six percent) and everything above would be reduced to six percent.

2. Medical trend estimates vary too much. The state should require a standardized

trend, either for the entire state or for regions. The carriers estimate medical trend between 5.1 and 11.5 percent. While most of the

trend requests are within the ranges seen in national estimates (between 4.5 and 8 percent), there are reasons to think that New York’s insurers could do a better job of managing these costs.19 For example, many of New York’s plans only offer in-network coverage and those networks are

18 Empire’s 2017 Rate Filing indicates that it had 54,000 members, while its 2019 filings now indicate that it has just 24,000 enrollees. In the interim, Empire retired its individual market offerings and re-filed a new product that was 47 percent more expensive than its predecessor. 19 American Academy of Actuaries, “Drivers of 2019 Health Insurance Premium Changes,” June 2018, http://www.actuary.org/files/publications/Premium_Drivers_2019_061318.pdf; Girod et al., “2018 Milliman Medical Index, May 2018, http://www.milliman.com/uploadedFiles/insight/Periodicals/mmi/2018-milliman-medical-index.pdf; and PwC Health Research Institute, “Medical Cost Trend: Behind the numbers 2019,” June 2018, https://www.pwc.com/us/en/health-industries/health-research-institute/assets/pdf/hri-behind-the-numbers-2019.pdf

www.hcfany.org Health Care For All New York Page 6

increasingly small.20 Most estimates of annual medical trend changes are based on information from the employer market, where networks and benefits are often more expansive. That could be a reason to believe that medical trend should be lower for New York’s narrow network plans.

Additionally, it is unclear why carriers in the same state and even in the same regions of

the state should report such variation in medical trend. Each year, HCFANY notes in our rate review comments that the carriers do not provide enough information about how they arrive at their trend estimates. While the applications have improved in some ways over the years (for example, fewer redactions), not enough applications include a breakdown of trend into pharmacy versus medical costs. When they do, the carriers rarely provide a narrative explanation of how they manage costs, other than to argue that provider consolidation means they cannot reduce medical spend.

As an intermediate step, the Department should consider requiring carriers to provide

better information about their trend estimates. The most helpful way for carriers to provide this information is through a trend breakdown showing the following: inpatient facility care, outpatient facility care, professional services, pharmacy, and other. This is helpful because it is the way that the Milliman Medical Index is reported, which provides a comparison point.21 Some carriers did provide that information, including Excellus, Healthfirst, and Independent Health. Additionally, if all carriers provided this information the public would be able to compare their own insurer’s performance to a statewide or regional average. HCFANY recommends that either Exhibit 18 or 13a be modified to require this information, or that the Department creates a new exhibit that shows a detailed trend breakdown.

More importantly, the Department should consider adopting a standardized medical and

pharmacy trend cap for individual market carriers and requiring them to stay under the state limit. This measure could be implemented on a statewide or regional basis.

3. Administrative costs should be decreasing over time. The Department should

consider imposing a cap to guard against extraordinary administrative costs. Overall plans are asking for slightly lower administrative costs this year (12.1 percent

versus 13.9 percent in their requests for 2018). But plans have had six years of experience operating in this market. New York State invests significant resources into marketing qualified health plans and making it easy for people to enroll and renew. The Department should investigate why administrative costs have not decreased more, and closely question plans whose administrative costs are increasing.

The range of administrative costs in the 2019 requests is also very wide, from 8.2 percent

to 17 percent. Companies that spend much more of their premium dollars on administrative costs than peers should explain their performance in a detailed manner. Above-average rate increases from companies that also have above-average administrative costs deserve special scrutiny. The 20 University of Pennsylvania/Robert Wood Johnson Foundation, “State Variation in Narrow Networks on the ACA Marketplaces,” August 2015, http://ldi.upenn.edu/sites/default/files/rte/state-narrow-networks.pdf 21 Girod et al.

www.hcfany.org Health Care For All New York Page 7

Department should also consider imposing a cap on administrative costs that are far above average.

II. Issues Specific to MVP

With nearly 30,000 enrollees, MVP is the largest carrier in the upstate New York region. In 2019, MVP seeks a relatively moderate 6.5 percent increase in premiums. While MVP has demonstrated good-faith efforts to keep costs manageable for consumers in the past, it nonetheless received a rate increase greater than it requested in 2018. HCFANY strongly believes that the Department should not grant rate requests that are higher than what a carrier deems necessary to operate, unless in its judgment such a rate is necessary to avert insolvency.

HCFANY urges the Department to closely review MVP’s 2019 rate application in the

following areas: trend, broker feeds and medical loss ratio.

A. MVP does not provide an adequate explanation of its high medical trend assumptions. In its rate filing for 2019, MVP’s requested trend is 7.89 percent, almost double the 4.5

percent projected by the Milliman Medical Index and slightly higher than the average 7.3 percent average requested for New York.22 MVP’s trend rate is also significantly higher than its upstate competitors—CDPHP (5.47 percent) and HealthNow (6.5 percent). More importantly, MVP’s 13.2 percent pharmacy trend is much higher than the carrier average of 10.1 percent and the second-highest overall:

Pharmacy Trend Estimates in 2019 Rate Applications for New York’s Individual Market Excellus 10.5% Healthfirst 11.5% HealthNow 10.2% Independent Health 16.5% MetroPlus 9.52% MVP 13.2% NYQHP/Fidelis 10.3% Oscar 6.7% Average 10.1%

MVP’s explanations for its trend assumptions are opaque. Similarly, MVP’s Actuarial Memorandum does not indicate that it expects any adverse changes in the risk profile of its 22 These are CDPHP, Empire Health Choice, Excellus, Healthfirst PHSP, HIP/Emblem Health, NYQHC/Fidelis, HealthNow, IHBC, MetroPlus, MVP Health Plan, Oscar, and Unitedhealthcare of New York. The applications cover both on-and off-exchange plans for all but MetroPlus and Oscar, which are only offering on-exchange plans. An additional four plans were offering plans off-exchange only, all with under 150 members. Those four plans were not included in the analysis for HCFANY’s individual rate comments. See Girod et al., “2018 Milliman Medical Index,” Milliman Research Report, May 2018, http://us.milliman.com/uploadedFiles/insight/Periodicals/mmi/2018-milliman-medical-index.pdf.

www.hcfany.org Health Care For All New York Page 8

enrollees other than to say that it assumes the overall market will shrink by 5 percent due to the individual mandate penalty repeal.

The Department may wish to devote extra scrutiny to MVP’s projected trend estimate,

given that MVP’s trend is higher than its competitors and, according to Milliman, medical trend has been steadily decreasing over the last 15 years. MVP should provide an explanation as to why its medical trend and pharmacy trend adjustments are so high and should provide a strategy for managing them.

Without a sufficient justification for such a high trend, HCFANY recommends that the

Department disallow a medical trend rate that exceeds the Milliman medical trend of 4.3 percent.

B. MVP’s broker costs may be too high. Although MVP’s broker costs have deceased since 2018, 0.9 percent for broker

commissions may still be too high. Many carriers have no broker costs at all. MVP’s Actuarial Memorandum does not indicate what percentage of its individual market enrollment is secured by brokers versus direct enrollment thorough the New York State of Health website, Certified Application Counselors, or Navigators. Moreover, MVP has a history of paying brokers above its expected rate in a given year.23

In light of the above, the Department may wish to disallow any broker adjustment in

2019.

C. The Department may wish to devote extra scrutiny to MVP’s requested rate increase given its history of projecting a high medical loss ratio. In 2015, MVP’s medical loss ratio was only 69 percent and thus did not meet the legal

requirement of 82 percent expenditure on medical claims. In 2017, MVP’s medical loss ratio skyrocketed to 96 percent, and that year MVP retained above-average profit across all carriers. MVP offers no explanation for these fluctuations. For the 2019 plan year, MVP projects its medical loss ratio to be 88 percent, while maintaining moderate administrative costs and retaining 1.5 percent profit. Given MVP’s history of oscillating medical loss ratios and above-average profit, the Department should carefully scrutinize MVP’s requested rate increase and consider lowering its rates.

23 See: MVP Actuarial Memorandum, Exhibit 18 Supplement, pg. 78.

www.hcfany.org Health Care For All New York Page 9

HCFANY urges DFS to carefully review the application submitted by MVP. Thank you for your attention to these comments. Please contact us with any questions at adunker@cssny.org or 212-614-5312.

Sincerely,

Amanda Dunker, MPH Mark Scherzer, Esq Health Policy Associate Legislative Counsel Community Service Society of NY New Yorkers for Accessible Health Coverage