2022 Rate Changes

Every year, I spend months painstakingly tracking every insurance carrier rate filing for the following year to determine just how much average insurance policy premiums on the individual market are projected to increase or decrease.

Carriers tendency to jump in and out of the market, repeatedly revise their requests, and the confusing blizzard of actual filing forms sometimes make it next to impossible to find the specific data I need. The actual data I need to compile my estimates are actually fairly simple, however. I really only need three pieces of information for each carrier:

  • How many effectuated enrollees they have enrolled in ACA-compliant individual market policies;
  • What their average projected premium rate increase (or decrease) is for those enrollees (assuming 100% of them renew their existing policies, of course); and
  • Ideally, a breakout of the reasons behind those rate changes, since there's usually more than one.

Unfortunately, there are about a dozen states where due to the carriers and/or the state insurance departments heavily redacting the rate filing documentation, I've been unable to fill in the actual number of people enrolled by some or all of the insurance carriers within that state's individual market. This means that the average premium rate changes listed (shown in grey) are unweighted averages, not weighted.

This can make a big difference in some cases: Let's say you have 2 carriers in a state, one raising rates by 10% and the other raising them by 1%. The unweighted average increase would be 5.5%. However, what if it turns out that the first carrier has 90% of the market share while the second only has 10%? That would mean a weighted average increase 9.1%. The unweighted average is the best I can do for these states without knowing the market share breakout, however.

As of this writing, I've plugged in the preliminary (requested) 2022 statewide average rate changes for all 50 states plus the District of Columbia, giving a national average increase of 3.9% overall. I've also entered the final (approved) averages for 19 states so far. For those states, the national weighted average increase is a bit higher, 4.8%. This will likely drop as more final averages are entered in the coming weeks hover; the odds are high that once every state is filled in, the final average increase will be slightly lower than the preliminary average.

UPDATE 10/19/21: I've filled in the final/approved averages for Oregon, Indiana, Delaware, Connecticut and Idaho, which collectively whittle the final national average down from 4.8% to...4.6%.

UPDATE 10/21/21: I've managed to get hard enrollment numbers (allowing weighted changes) as well as approved rate changes for North Dakota, Arizona and South Carolina. In addition, Wisconsin's insurance dept. issued their weighted, approved average as well.

With these updates, the preliminary national average increases to 4.1%, while the approved average (across 29 states) is down to 4.2%.

UPDATE x2 10/21/21: OK, I'm on a roll today: I've also managed to get more accurate enrollment data for Alabama as well as confirming AL's approved rate changes, and have also filled in the enrollment data for Iowa carriers (again, confirming approved changes), which allowed me to run the weighted average statewide. None of these changes moves the needle on either preliminary or approved rate changes, however.

UPDATE 10/22/21: Added approved rate changes for Colorado, Michigan & Montana.

UPDATE 10/27/21: Added approved rate changes for Ohio, Tennessee, South Dakota, North Carolina & Arkansas, along with some updates/corrections to enrollment data & carrier participation for a few other states.  Also revised estimated total market enrollment for the 7 states which I don't have hard data available for.

UPDATE 11/02/21: Now that the 2022 Open Enrollment Period has officially launched, the federal Rate Review website has been updated with approved rates for all 50 states + DC, allowing me to fill in the remaining states.

Overall, it looks like the average unsubsidized rate increase is around 3.5% nationally.

(click image for higher-resolution version)

Mississippi

Louise Norris beat me to the punch on Mississippi this year:

Cigna is joining the Mississippi exchange for 2022, bringing the total number of participating insurers to three. According to ratereview.gov, the following average rate changes have been proposed by Mississippi’s current exchange insurers:

Minnesota

The Minnesota Commerce Dept. has posted preliminary 2022 ACA rate filings for the individual and small group markets. Final/approved rate changes will likely be posted in just a few weeks.

Overall I don't see any significant changes to the offerings from 2021 other than PreferredOne appearing to eliminate one of their two lines on both markets. Also, UnitedHealthcare of Illinois appears to be scrapping their entire line of existing plans on the small group market and replacing them with all-new policies, which means there's technically no current rates for them to compare against.

The other important thing to keep in mind for the small group market is that I can't seem to find the actual current enrollment data for each carrier, so I'm basing the weighted average on 2020 enrollment, which could be way off if there's been significant market share shifts this year.

Massachusetts

Massachusetts, which is arguably the original birthplace of the ACA depending on your point of view (the general "3-legged stool" structure originated here, but the ACA itself also has a lot of other provisions which are quite different), has 9 different carriers participating in the individual market. MA (along with Vermont) has merged their Individual and Small Group risk pools for premium setting purposes, so I'm not bothering breaking out the small group market in this case.

Getting a weighted average for Massachusetts is trickier than in most states, for a couple of reasons. The good news is there's an August 2021 enrollment report which breaks out exactly how many MA residents are enrolled in each carrier's policies. However, the numbers are actually broken into 4 different categories: Small Group (which, again, is merged with the individual market in MA); "ConnectorCare" individual market policies; subsidized Qualified Health Plans and unsubsidized QHPs.

Maryland

Back in June (yeah, I'm way behind as I've said before), the Maryland Insurance Commissioner published the preliminary 2022 rate filings for the state's individual and small group markets:

Health Carriers Propose Affordable Care Act (ACA) Premium Rates for 2022 Public Invited to Submit Comments

BALTIMORE – The Maryland Insurance Administration has received the 2022 proposed premium rates for Affordable Care Act products from health carriers. Health carriers are seeking a range of changes to the 2021 premium rates for plans sold in Maryland’s Individual Non-Medigap (INM) and Small Group (SG) markets in 2021.

Maine

The Maine Insurance Dept. (technically the Dept. of Professional & Financial Regulation) has issued final approval of 2022 health insurance rate filings for the individual and small group markets.

Not much is changing next year--average individual market premiums will be dropping by 2.1%, while average small group rates will be going up 3.1%. There's a new entry into Maine's small group market (UnitedHealthcare of New England, not to be confused with UnitedHealthcare Insurance, which is already offering small group policies).

Louise Norris provides some additional details on Maine's upcoming ACA market changes:

Louisiana

Louisiana's rate filing database is frustrating, because it's both highly-detailed and confusing at the same time.

They break out the filings not between Individual and small group markets or on- vs. off-exchange policies, but between rate increases over and under 10%. Normally that would be fine, but they also have multiple listings within each market for several carriers; HMO Louisiana, in fact, has 11 entries, each for a different product line, making it tedious and difficult to piece together the weighted average rate change and current enrollment for the carrier as a whole.

In addition, it looks like the state regulators have given final approved rate changes for 2022 in some cases but not others...even within the same carrier and market.

As a result, my weighted averages below may be off somewhat.

With that in mind, it looks like Louisiana's individual market is looking at final average rate hikes of 4.75%, while their small group market carriers are seeking preliminary increases of around 6.9%.

Kentucky

Well, this was inevitable: I got so far behind on my annual ACA rate filing project that the final/approved rates have started to be released before I even get around to some of the preliminary/requested rate filings.

The Kentucky Insurance Dept. has posted both the requested and approved 2022 rate filings for the individual and small group markets, and in addition to drastically slashing the average premiums for Anthem's individual market offerings and Aetna's small group offerings, there's also two new entrants into Kentucky's individual market: Molina and WellCare.

Overall, individual rates are dropping by around 3.8% on average (the carriers had requested a 2.7% increase), while small group market plans are increasing by 10.4% on average (very close to the 10.7% average request).

Kansas

(sigh) Once again, the Kansas Insurance Dept. is supremely unhelpful when it comes to providing information about individual & small group market health insurance premium rate changes. Not only are the ACA plans not listed in the state's SERFF database or on the department's website, even the actuarial memos available at the federal Rate Review website are heavily redacted. As a result, I only have the actual enrollment numbers for a handful of carriers, preventing me from being able to calculate a weighted average (or to estimate the state's total ACA enrollment size, for that matter).

The unweighted average rate increase on Kansas' individual market is +8.3%, and it's +5.6% for the small group market, anyway.

UPDATE 10/22/21: No approved rates yet, and no changes to any of the numbers, but it looks like there's actually two new carriers joining the Kansas individual market (Sunflower State and US Health & Life), as well as one joining the small group market (Cigna):

Iowa

(sigh) Unfortunately, the Iowa Insurance Department is pretty much useless when it comes to individual & small group market rate filing transparency. I can't find any press releases or statements about the 2022 rate filings, they don't list the 2022 Individual market filings at all, their Small Group market filing database is available but a year out of date, and they don't even list any of the ACA-compliant plan filings in the SERFF database.

The only way I was able to find the rate changes was by using the federal Rate Review website, and even then, the actuarial memos are all heavily redacted, making it impossible to know what the enrollment for each carrier si (with one exception: Wellmark Health Plan reported having 32,000 ACA-compliant individual market enrollees as of March 2021).

Indiana

The Indiana Insurance Dept. doesn't seem to have issued a formal press release about this (or if they did, I can't find it), but they've quietly posted their preliminary 2022 health insurance premium rate change requests for both the individual and small group markets:

The overall average rate increase for 2022 Indiana individual marketplace plans is -1.65%.

Anthem, CareSource , US Health and Life, and Celtic (MHS/Ambetter) have filed to participate in the 2022 Indiana Individual Marketplace.

Anthem has also filed to offer an Off-Marketplace catastrophic plan in Benton, Jasper, Newton, Warren and White Counties.

The IDOI will finalize the review of the 2022 ACA compliant filings both on and off the federal Marketplace by September 22, 2021.

It looks like US Health & Life is new to the Indiana individual market, while UnitedHealthcare of KY is new to the small group market. Unfortunately I couldn't find the actual small group enrollment number for either Physicians Health Plan or Southeastern Indiana Health on the sm. group market, and the IU Health Plan number is an estimate.

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