Although the majority of announcements won’t come until later this summer, the first few state ACA rate filings for 2027 have been posted during the last several days — and more are coming every day.
State-Specific Information: Alabama · Alaska · Arizona · Arkansas · California · Colorado · Connecticut · Delaware · Florida · Hawaii · Idaho · Illinois · Indiana · Iowa · Kansas · Kentucky · Louisiana · Maine · Maryland · Massachusetts · Michigan · Minnesota · Mississippi · Missouri · Montana · Nebraska · Nevada · New Hampshire · New Jersey · New Mexico · New York · North Carolina · North Dakota · Ohio · Oklahoma · Oregon · Pennsylvania · Rhode Island · South Carolina · South Dakota · Tennessee · Texas · Utah · Vermont · Virginia · Washington · West Virginia · Wisconsin · Wyoming
What is this?
How can I make my voice heard?
These filings are submitted every year as part of the Affordable Care Act’s rate review requirements, as explained on HealthCare.gov:
The Affordable Care Act (ACA) requires that insurers planning to significantly increase plan premiums submit their rates to either the state or federal government for review.
The rate review process is designed to improve insurer accountability and transparency. It ensures that experts evaluate whether the proposed rate increases are based on reasonable cost assumptions and solid evidence and gives consumers the chance to comment on proposed increases.
The ACA also requires that a summary of rate review justifications and results be accessible to the public in an easily understandable format.
Charles Gaba over at ACASignups.net does a great job crunching the numbers, but only briefly mentions the public comment periods. Those comment periods are an important part of the rate review process for the following reasons:
- While regulators are not required to modify rates based on public comments, those comments become part of the public record and can help draw attention to assumptions, methodologies, or market conditions that may warrant additional scrutiny.
- In addition, most states limit comment periods to 30 days, so it’s important to send comments in as soon as possible.
- Comments can be made by anyone from the general public. You do not have to be an expert about health insurance to express your opinion.
To be transparent: In most states, I’m pulling the information directly from the applicable Department of Insurance. I am also using other media sources in addition to Mr. Gaba’s work.
Aren’t these only for individual/family plans?
I get my health insurance through my employer.
You might still be affected! ACA rate filings are for both individual/family plans and fully insured plans for employer groups with fewer than 50 (100 in California and Colorado) eligible employees.
Different states also use different methodology for counting eligible employees. For information about your specific employer, ask your human resources office.
My employer says it is not subject to ACA rating requirements.
Should I still care?
It’s not unusual for an employer-sponsored plan to be exempt from ACA rating requirements. The two most common reasons for an exemption are (a) because the employer has more than 50 (or 100) eligible employees and/or (b) the employer’s plan is fully or partially self-funded.
But even for those who aren’t directly affected, the ACA rate filings provide an early glimpse into broader health care cost trends. When setting rates for their other policies, carriers often use the same factors as those used for their ACA plans: changing hospital costs, prescription drug and medical procedure usage, provider shortages, and similar issues. The rate filings also often suggest a carrier’s particular marketing strategy for the upcoming year.
More than that, the ACA rate review process gives consumers something that is often missing from discussions about health insurance costs: visibility. By requiring carriers to publicly explain proposed premium increases and giving the public an opportunity to respond, the process helps ensure that decisions affecting millions of policyholders are not made entirely behind closed doors.
Whether you ultimately agree with a carrier’s reasoning or not, transparency is valuable. Understanding why rates are changing is the first step toward having an informed discussion about what should happen next. Regardless of whether — or how — a proposed increase is announced and justified, the people paying those premiums deserve to understand why.
When and how do I submit a comment?
Each state sets its own rules and processes. In the next few posts, and in others throughout the filing season, I’ll review the proposed increases in each state, explain how to submit comments, and highlight important deadlines.
If you care about health insurance affordability, don’t wait until Open Enrollment to start paying attention. By then, the rates have already been approved.
The public comment period is one of the few opportunities consumers have to make their voices heard before those decisions are finalized. Whether you support a carrier’s proposal, oppose it, or simply have questions about the assumptions behind it, submitting a comment helps ensure that regulators hear from the people who will ultimately be affected by their decisions.
I’ll also be following up as states issue their final decisions. Since the filing season generally runs through mid- to late September, there will be plenty more to discuss in the weeks ahead.