FREQUENTLY ASKED QUESTIONS:
HEALTH INSURANCE
RATES AND THE
REVIEW PROCESS
INSURANCE ADMINISTRATION
FREQUENTLY ASKED QUESTIONS:
HEALTH INSURANCE
RATES AND THE
REVIEW PROCESS
INSURANCE ADMINISTRATION
HEALTH INSURANCE RATES AND THE REVIEW PROCESS
Maryland Insurance Administration • 800-492-6116 • www.insurance.maryland.gov
TABLE OF CONTENTS
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
Frequently Asked Questions and Answers:
What Coverages are Subject to Rate Review ..................1
How Health Insurance Companies Develop Rates .............2
What Causes Rates to Change.............................3
e Rate Review Process .................................5
What is the 1332 State Innovation Waiver ...................8
Other Topics ..........................................8
Learn More .........................................10
Denition of Terms....................................12
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
Since premiums are important in deciding whether you can aord a specic
health insurance policy, it is important to understand some of the factors that
aect premiums. Here are a few questions that consumers often ask the Maryland
Insurance Administration (MIA) about the health insurance premiums they pay.
e “premium” is what you pay when the rate has been adjusted based on your age,
deductible, copayment levels, and other factors. e term “rate” means the amount
the insurance company uses to determine your premium.
WHAT COVERAGES
ARE SUBJECT
TO RATE REVIEW?
e Oce of the Chief Actuary of the MIA reviews rates for:
1. Individual Medicare Supplement insurance (Medigap);
2. Individual Non-Medigap health benet plans (grandfathered
1
and ACA
2
));
3. Small Group health benet plans (50 or fewer employees (grandfathered
and ACA));
4. Large Group health benet plans (51 or more employees) that are not self-
insured;
5. Long Term Care Insurance (LTC); and
6. various other types of health insurance, including Stop Loss, Accident,
Disability Income, Specied Disease or Illness (e.g., cancer, critical illness,
organ transplant, complications of cosmetic surgery), Hospital Indemnity,
Fixed Indemnity, Dental (non-ACA and ACA), Vision, Student (ACA),
and Short-Term Limited Duration Health Insurance (STLDHI).
Rate lings for Property and Casualty policies are handled in a separate department
of the MIA.
1 A grandfathered plan is an individual health plan purchased on or before March 23, 2010, whose benets have
not substantially changed. ese plans are not required to comply with benet requirements of plans provided under
the Aordable Care Act and will include a statement indicating that it is a grandfathered plan.
2 An ACA plan is a plan that complies with the federal Aordable Care Act.
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
e Maryland Department of Health, in consultation with the MIA, establishes the
Medicaid rates.
e MIA does not review rates for:
Large Groups that are self-insured (including “ird Party Administrators
(TPA));
Federal plans such as Medicare (e.g., Medicare Advantage, Medicare Part
D), and TRICARE (formerly “Civilian Health and Medical Program of
the Uniformed Services” (CHAMPUS));
Programs for federal employees (e.g., Federal Employee Health Benet
Program (FEHBP) and Federal Employee Dental and Vision Insurance
Program (FEDVIP));
Federal LTC Insurance; and
Plans issued in other states.
HOW HEALTH
INSURANCE COMPANIES
DEVELOP RATES
1. HOW DO CARRIERS DEVELOP RATES?
Carriers use data to predict how much they need to charge to pay claims and
operating costs, including prot. Carriers project future claims and operating
costs, both in the aggregate and for specic subgroups (or “stratications”) who
share a common trait. Stratications can include benet plan, age band, or region.
In making these projections, carriers make certain assumptions. Some of the key
assumptions include claims trend, risk adjustment, whether the pool of insureds
is getting older or sicker overall, legal changes (such as the Aordable Care Act’s
requirements), prot need, how much insureds pay in cost-sharing (deductibles,
coinsurance), state and federally-based programs (such as reinsurance), and drug
manufacturer rebates.
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
2. HOW DO CARRIERS ESTIMATE CLAIM COSTS?
Carriers analyze past actual experience by types of services, and which services are
being used more or less often. Some categories of services include inpatient hospital,
outpatient hospital, professional, other medical (e.g., home health, prosthetics),
capitations, and prescription drug. e Health Service Cost Review Commission
(HSCRC) sets hospital budget constraints each year in June, and carriers also
use this information in their estimates. Carriers also develop models of member
behavior to determine, for example, whether wellness programs or cost sharing
aects how many health care services members receive. Changes in the mix of
services and/or places of services (e.g., hospital setting versus ambulatory surgical
center (ASC), doctor’s oce or emergency room) can be examined as well; dierent
settings have dierent costs, so more services in an expensive setting can drive up
costs. New technologies or drugs (e.g., biologics) are considered, as are changes in
the insured’s cost-sharing.
WHAT CAUSES RATES
TO CHANGE
1. WHAT FACTORS CAN CAUSE RATES TO CHANGE?
Rates are determined in large part by medical spending. Medical costs can change
for many reasons, including increases in provider charges, greater use of health
care services, new technologies, costs for prescription drugs, an aging population,
and unhealthy lifestyles. A carrier also may change its rates because it needs to
increase its reserves to pay future claims. Premiums must be high enough to cover
the companys projected claims and operating costs. Changes to laws, government
subsidies, and risk proles of the insured population can also be factors.
2. WHY DID MY RATES GO UP WHEN I DIDN’T HAVE ANY CLAIMS
(DIDN’T SEE A DOCTOR, GO TO THE HOSPITAL, OR GET ANY
PRESCRIPTIONS)?
Your premium will not go up solely because you have claims, just as it will not
go down solely because you do not have claims. People buy insurance to protect
themselves from the full nancial risk of future events. Insurance is a pooling of
risks. e goal is to set premiums so that there will not be big swings from year to
year due to one or two very large claims. If you have an individual or small group
policy, your premium is based on the claims of everyone with your type of policy.
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
If you have coverage under a large employer health plan, your premium will be
based in part on the claims of everyone in your group. Insurers can predict the type
of claims they are likely to pay, and set premiums so that the costs are spread out
across the pool.
3. WHAT CAUSES MY PREMIUM TO INCREASE AT A DIFFERENT RATE
THAN OTHERS WITH THE SAME POLICY?
If you buy your own health insurance, your specic premium may change due to
your: 1) age (aging one year has diering impacts and, generally, the cost increases
with age since you are more likely to le claims as you get older); 2) selected benet
plan, including the deductible level you select and applicable copays; 3) family
composition change; or 4) location/residence change since some areas of the state
have higher costs than other areas. Your insurance producer or carrier can help
identify the exact cause in your situation.
If you have coverage through your employer, your premium includes both the
amount you pay and the amount your employer pays. If your employer pays less, it
may seem like a premium increase even if the actual premium is the same. You may
also pay a dierent amount if you select a new benet plan, add or remove family
members, or move. (Rates for the whole group may change dramatically for groups
if the average age changes signicantly.) Your human resources benets oce should
be able to assist.
4. HOW OFTEN CAN MY PREMIUMS CHANGE?
Generally, premiums cannot change more than once every 12 months (or the plan
year). However, carriers are permitted to raise or lower premiums more frequently
than once every 12 months if the change is only because you added or removed
family members from the policy. For non-ACA products, premiums may also
change during the plan year if benets change or optional riders are added or
removed. Also, in the Individual non-Medigap ACA market, rates change every
January 1. erefore, if someone purchases a policy after January 1 in a given year,
his/her rate can change on the next January 1 for the rst renewal period, even if
though it has been less than 12 months since the policy was purchased.
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
5. MUST CARRIERS SUBMIT RATE FILINGS EACH YEAR?
In most cases, carriers only need to submit a rate ling if they are requesting a
change in rates. However, carriers must submit rate lings for Medicare Supplement
plans annually, even if they are not requesting a change in rates. In addition, carriers
must submit a certication each year for small group policies, conrming that the
rates charged during the past year complied with the law.
THE RATE REVIEW
PROCESS
1. DOES ANYONE REVIEW CARRIERS’ RATE CHANGES BEFORE THEY
GO INTO EFFECT?
Yes. Maryland law requires carriers to le rates and have them approved by the MIA
before implementation.
2. WHO REVIEWS RATE CHANGE REQUESTS AT THE MIA?
e MIAs Oce of the Chief Actuary (OCA), which is staed by credentialed
actuaries, is responsible for reviewing all led rates for health benet plans.
Actuaries are insurance professionals trained to analyze risks and develop premium
rates. Credentials are earned from the Society of Actuaries (SOA) and the American
Academy of Actuaries (AAA) through extensive study, testing, practical experience,
and training. Continuing education requirements must be fullled annually for
credentialed actuaries.
3. HOW DOES THE MIA DECIDE WHETHER TO APPROVE A
REQUESTED RATE CHANGE?
Carriers must demonstrate that requested rates comply with Maryland law.
Specically, Section 11-603(c)(2) of the Insurance Article, Annotated Code of
Maryland requires that rates be based on reasonable assumptions, and that rates
are not inadequate, unfairly discriminatory or excessive in relation to benets.
An excessive rate reduces access and aordability. An inadequate rate means
the company may not be able to pay claims in the long run. A rate is unfairly
discriminatory if, for example, it is not applied consistently to members of the same
demographic or benet rating prole.
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
Additionally, federal and state minimum loss ratios must be projected to be met.
Under the ACA, if the actual loss ratio falls below 80.0% for the Individual Non-
Medigap, Small Group , or Student ACA markets and 85.0% for Large Groups
(fully insured), rebate checks must be issued by the carrier to the contract holder or
employer.
All of the assumptions outlined above are tested and examined in detail by the
MIAs OCA. “Net income” and “gains/losses from operations” from nancial
statements provide context.
4. WHAT OTHER INFORMATION DOES THE MIA EXAMINE WHEN
REVIEWING A RATE CHANGE REQUEST?
Model laws and regulations adopted by the National Association of Insurance
Commissioners (NAIC) are reviewed, and sometime adopted by the MIA for
rate review. e MIA considers the history of rate changes, the carriers’ nancial
strength, the absolute level of the rate versus competitors in the market, and the
comparison of renewal rates to new business rates. If rates need to go up, the MIA
considers how quickly the rates can rise. Sometime the rise is gradual and spread
over multiple years. Mathematical computations are also checked for accuracy. Each
year, new market dynamics lead to new information being requested by the MIA
(e.g., for 2019 rates the Tax Cuts and Jobs Act (TCJA)). For small sample sizes, the
credibility of the data is measured. Additionally, if the carrier delayed correcting
rating missteps, that may reduce a requested rate increase. If a carrier is partly to
blame for incorrect assumptions, that can also reduce a requested rate increase.
Oftentimes, carriers take the prior two actions on their own.
5. DO CARRIERS ALWAYS GET APPROVAL FOR THE RATE CHANGES
THEY REQUEST?
No. A rate request will be modied if it is not proven to be fully justied and/
or suciently supported. A rate request will be withdrawn if the carrier does
not respond. A rate request will be denied if it is not proven to be needed. In
some cases, a carrier is asked to withdraw a ling if it aects a small number of
Marylanders (e.g., less than 10) where a rate approval would have little impact to
the carrier, but a big impact to the member.
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
6. CAN THE MIA APPROVE A REQUESTED RATE CHANGE FOR SOME
POLICIES AND DENY A REQUESTED RATE CHANGE FOR OTHER
POLICIES FOR THE SAME CARRIER?
Yes. e MIA reviews the rates for each health benet plan. If the rates for some
plans are not supported, the requested rates for those products are not approved.
7. WHAT IF THE CARRIER DISAGREES WITH THE MIA’S DECISION?
e carrier has the right to request a rate hearing if it disagrees with the MIAs rate
ling decision.
8. DO CARRIERS HAVE TO NOTIFY POLICYHOLDERS ABOUT RATE
CHANGES?
Yes. Maryland law requires carriers to provide an annual notice to their
policyholders, and to post a notice on their websites, explaining that policyholders
may nd proposed ACA rate changes on the MIAs website. Depending upon
the type of health benet plan (e.g. individual or group, grandfathered or
nongrandfathered, or Medicare Supplemental insurance), a notice of a rate increase
must be received 30 to 60 days prior to the eective date. LTC insurance carriers
must provide notice at least 45 days prior to the eective date and are also required
to provide the form number annually so that policyholders may identify rate lings
and hearings that pertain to their plan.
9. IS THERE A FORUM FOR PUBLIC COMMENTS?
Public comments are an important part of the process. In the past, excerpts have
been shared at MIA hearings, with the press, with carriers, and with legislators in
Annapolis. ACA individual non-Medigap market and small group rate lings are
open to public comment. When a carrier submits a rate change request, consumers
can read the carriers justication for the request and submit comments on the
MIAs website for at least 30 days from the date the request is posted on its website.
10. HOW OFTEN ARE ACA RATE HEARINGS HELD?
e answer depends on the specic plan and carrier. A rate hearing is required prior
to approval and any LTC ling. LTC hearings have been held quarterly since 2015.
Generally speaking, there have been 1-2 hearings per year since inception for ACA
plan rates eective since 2014.
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
11. HOW LONG DOES THE RATE REVIEW PROCESS TAKE?
From submission to approval, it usually takes between 10 days to more than a
year to complete the rate ling review process; ACA lings usually take about four
months. During this time, the MIA may ask carriers for additional data, and the
carrier then has 10 days to respond to the request unless an extension is requested.
WHAT IS THE 1332 STATE
INNOVATION WAIVER?
FOR THE ACA, WHAT WAS THE SIGNIFICANCE OF THE SECTION 1332
STATE INNOVATION WAIVER APPROVAL?
Under the Aordable Care Act, a state can ask the federal government to waive
certain requirements; this is known as a Section 1332 waiver request. On August
22, 2018, the Centers for Medicare & Medicaid Services (CMS) approved
Maryland’s request to deviate from federally-prescribed rating practices for the ACA
and to allow a state-based reinsurance program (SBRP) eective 2019, in an eort
to help lower premium rates. Maryland became the seventh state to implement a
SBRP. e 2020 rates submitted by the carriers for the individual non-Medigap
market include the estimated impacts from the SBRP. For 2019, the overall rate
impact of the SBRP was -30% ranging from -45% to -27% by legal entity.
OTHER TOPICS
1. HOW MIGHT THE 2020 ACA INDIVIDUAL NON-MEDIGAP FILINGS
AFFECT SUBSIDIES?
On March 1, 2019, carriers submitted benet plan carriers submitted their
proposed benet plans. Twenty benet plans have been led On-Exchange
compared to only seventeen last year. An area of close examination has been the
impact on the benchmark “second lowest cost Silver plan” (SLCSP). e dierence
between the SLCSP premium and the IRS-dened maximum amount that those
earning under 400% of the Federal Poverty Limit (or $49,960 for an individual in
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
2019) will pay is the “Advance Premium Tax Credit” (APTC) or subsidy. Based on
the carriers’ lings to date, despite the average rate decrease, preliminary estimates
indicate that subsidies could still increase in both rural regions where only CareFirst
(CF) is available, and regions where both CF and Kaiser (KP) are available by +10%
and +4%, respectively, for those earning 150% of FPL ($18,735 for an individual).
2. FOR THE INDIVIDUAL NON-MEDIGAP ACA MARKET, WHAT ARE
THE NEW “VALUE” PLANS?
“Value” plans have been added with more rst-dollar coverages, preventive services,
and less insured cost-sharing. More details are available at the link below.
3. FOR THE ACA INDIVIDUAL NON-MEDIGAP MARKET, WHY ARE
RATES HIGHER FOR SILVER PLANS AVAILABLE ON THE MARYLAND’S
HEALTH BENEFIT EXCHANGE (MHBE) THAN THOSE AVAILABLE OFF
OF THE MHBE?
Tax credits are based on the premiums for Silver Plans available on the Maryland
Health Benet Exchange (On-Exchange Silver Plans). In 2018, the federal
government stopped funding “cost-sharing reductions” (CSRs), and carriers in turn
increased their premium rates to replace the federal CSRs payments. Maryland
required that carriers apply this new cost only to Silver-On Exchange rates to
maximize subsidies. As a result, for Silver Plans, similar to last year, On-Exchange
rates are 9%-19% higher than O-Exchange rates.
e On and O-Exchange Silver Plans cover the exact same Essential Health
Benets (EHBs)
3
, with identical cost-sharing on those EHBs. EHBs represent more
than 99% of claims. e key dierences between the on and o exchange silver
plans though are that the O-Exchange plans lack coverage for certain non-EHBs,
but may cost less and be a good value for people who do not qualify for subsidies.
To reiterate, subsidies are only available On-Exchange. ose subsidies may still
enable a lower nal premium for a Silver Plan. e subsidy could make a Bronze
Plan available for free or a richer Gold Plan at a good overall value.
3 e federal Aordable Care Act requires that individual and small group plans (these plans are available for
employers with 50 or fewer employees) that are not grandfathered plans and that began or are renewed on or after
January 1, 2014, provide certain benets. ese benets are called, “Essential Health Benets”. For more information
about essential health benets for individual and small group health benet plans in Maryland, see the MIAs Essential
Benets Chart, (link to: https://insurance.maryland.gov/Consumer/Documents/publicnew/essentialbenetschart.pdf)
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
4. HOW DOES MARYLAND’S REINSURANCE PLAN (SBRP) PROGRAM
WORK?
When the federal government announced another moratorium for 2019 of the
ACA “health insurer fee” (HIF), Maryland enacted legislation to redirect it to fund
a RI program since it was already in rates. is generated approximately $365
million dollars. For 2019, claims will be reinsured above $20,000 up to $250,000
with 80% coinsurance in between. By using the $365 million to reduce rates the
federal governments Maryland subsidy payments go down. e federal government
passes this savings to Maryland, estimated over three years at $779 million so
that the total program size becomes $1.144 billion, leveraging the $365 million.
e ACA Individual Non-Medigap premium impact for the years 2019, 2020,
and 2021 has been estimated at -30%, -30%, and -14%, respectively. However,
legislation enacted during the 2019 General Assembly Session added 1.0% annually
through 2023 to augment the $365 million.
LEARN MORE
HOW CAN I FIND OUT MORE ABOUT RATES AND RATE CHANGES
REQUESTED BY CARRIERS?
Rate Filings and Supporting Documents
Public access is available shortly after submission and public comments may be
entered and viewed. e supporting documentation for individual non-Medigap
and Small Group ACA rate lings submitted by carriers can be found on the OCAs
web site for data and public comments; www.healthrates.mdinsurance.state.md.us.
At this site you will nd “frequently asked questions” (FAQs), led rates, the
actuarial memorandum (a.k.a., Part III), a written description of the ling (a.k.a.,
Part II), the “Unied Rate Review Template” (URRT), the press release, and notices
about upcoming hearings.
e national system that houses rate lings is called the “System for Electronic
Rate and Form Filing” (SERFF). Upon approval, the nal support can be viewed
along with correspondence between the MIA and the carriers along with a
decision document” outlining key reasons for the approval rendered for lings for
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
all markets. An archive of past approvals is available for public viewing, and can
be viewed at https://lingaccess.ser.com/sfa/home/MD. Carriers can redact certain
portions of the actuarial support. If they do, the public can still submit a “Public
Information Act” (PIA) request to see the unredacted version. Rate guides for
Medigap are also available. Below are some links outlining available resources.
PIA
https://insurance.maryland.gov/Pages/public-information-act-requests.aspx
Rate Review Process
https://insurance.maryland.gov/Consumer/Pages/HealthInsuranceRateReviewProcess.aspx
LTC for data and public comments
https://insurance.maryland.gov/Consumer/pages/LongTermCare.aspx
Medicare Supplement Rate Guide
https://insurance.maryland.gov/Consumer/Documents/publications/Medicare-
Supplement-Rate-Guide.pdf
MHBE
https://www.marylandhbe.com/wp-content/uploads/2012/10/Carrier-Reference-Manual.pdf
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
DEFINITION OF TERMS
Actuarial Value (AV): e ratio of the paid amount to the allowed amount. Said
another way, this is a measure of the richness of the benet plan. It is the portion or
percentage of the health care bill paid by the carrier after insured cost-sharing.
Allowed Amount: e cost of a medical service from a hospital or physician with
discounts negotiated by carriers. (Discounts can be substantial (e.g., as much as
-50%)).
Billed Charges: e cost of a medical service from a hospital or physician without
discounts negotiated by carriers.
Carrier: An insurer, Health Maintenance Organizations (HMO), dental plan
organization, or nonprot health service plan.
Claims Costs: e amount a carrier pays for health care services and goods, such as
physician services, hospital fees, durable medical equipment (DME), dental, vision,
and prescription drugs, on behalf of policyholders. is amount does not include
any deductible or copayment paid by the policyholders.
Claims Trend: Annual increase in “cost per service” (intensity) and “utilization/
services per member” (frequency).
Cost-Sharing Reductions (CSR): Reduced insured cost-sharing plans oered
under the ACA in the Individual Non-Medigap market for Silver plans On-
Exchange only, which are available to those earning between 100% and 250% of
the Federal Poverty Level (FPL) in three tranches of “actuarial value” (AV) of 73%,
87%, and 94%.
First-Dollar Coverage: Benets for which a member does not pay a deductible.
However, copays or coinsurances may apply.
Health Benet Plan (HBP): A contract stipulating benets for medical care
oered by a carrier to an individual, group, or Association. is does not include
excepted benets insurance such as accident-only, disability income, worker’s
compensation, automobile medical payment insurance, credit-only insurance, long
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
term care (LTC), specied disease, hospital indemnity, xed indemnity, Medicare
Supplement, liability supplement insurance, on-site medical clinics, and limited
scope dental or vision.
Health Insurer Fee (HIF): A charge to health insurers (including HMOs) based on
each insurers share of the taxable health insurance premium base (among all health
insurers of U.S. Health Risks) to fund the ACA. Carriers estimate that this fee will
amount to about 3% of premium in 2020.
Individual Mandate: A federal requirement under the Aordable Care Act as
enacted that individuals obtain qualifying health insurance coverage or pay a tax
penalty.
Insured Cost-Sharing: e portion of the claims cost paid by the member before
the carrier starts to pay. It includes deductibles, copayments, and coinsurance
amounts up to the out-of-pocket maximum.
Medical Loss Ratio (MLR): e percentage of the premiums that go toward claims
cost (e.g., 80.0%).
Metal Level: An ACA categorization of benet plans based on AV or benet
richness. e least rich is Bronze (central AV = 0.60), the most rich is Platinum
(central AV = 0.90), and in between are Silver (central AV = 0.70), and Gold
(central AV = 0.80).
Morbidity: A measure of the relative health of a population.
Operating Costs: e non-claims costs incurred by a carrier such as administrative
expenses, taxes, fees and assessments (federal and state), and payments to brokers.
e costs of administering a health plan can include overhead (e.g., rent, salaries),
computer systems, provider network maintenance, and fraud detection.
Paid Amount: e portion of the allowed amount paid by the carrier after insured
cost-sharing.
Prot/Contribution to Reserve: e remaining money after all claims and
operating costs have been paid in a given year, before investment income. ese
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HEALTH INSURANCE RATES AND THE REVIEW PROCESS
funds go into surplus to protect against future volatility in business operations,
and for purposes such as investing in infrastructure to improve customer service,
or marketing. Surplus suciency is measured by a statistic called a “Risk-Based
Capital” (RBC) ratio. (“Contribution to Reserve” is the term used for nonprots.)
Reinsurance (RI): A nancial program whereby someone other than the carrier
pays a portion of the claims costs in a given year.
Risk Adjustment (RA): Federal program under the Aordable Care Act (ACA) to
compensate carriers who enroll relatively sicker members and vice versa. It seeks to
equalize/level the eld” by transferring money from insurers with healthy members
and low claims costs to those with relatively unhealthy members and high claims
costs.
Drug Manufacturer Rebates: Dollars given back to insurers or pharmacy benet
managers (PBMs) from pharmaceutical companies in return for prescribing
certain drugs.
MIA-RX-1 (11/19)
is consumer guide should be used for educational purposes only. It is
not intended to provide legal advice or opinions regarding coverage under a
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