How Repeal of the Individual Mandate and Expansion of Loosely Regulated Plans are Affecting 2019 Premiums

Data were collected from publicly available health insurer rate filing submitted to state regulators for ACA-compliant coverage offered on- and off-exchange. Most rate information is available in the form of a SERFF filing (System for Electronic Rate and Form Filing) that includes a base rate and other factors that build up to an individual rate. For some states where approved filings were unavailable, we gathered data from preliminary information released by state insurance departments and healthcare.gov. We did not group subsidiaries by parent company as some subsidiaries within a given state made differing assumptions.

We exclude insurers where the individual mandate penalty was not specified in the public rate filings. We assigned these insurers a value of “NA,” meaning the company (1) did not mention the individual mandate, STLD, or AHPs at all; (2) mentioned an impact but did not quantify the amount; or (3) quantified the rate impact but redacted the amount from public filings. In some cases, we assigned a value of “NA” when it was clear the insurer requested a rate impact but it was unclear whether the state allowed that load, or if the insurer built in the load elsewhere in their rate calculations. A value of “0%” means the insurer did publicly quantify the impact and specified that it was 0%.

We exclude from this analysis states that have implemented their own individual mandates (Massachusetts, New Jersey, and Washington, DC) or, in the case of New York, prohibited insurers from loading an individual mandate surcharge into 2019 premiums.