Excellus Health Plan, Inc. Individual 2022 Public Comments

Excellus Health Plan, Inc.
Individual
2022 Public Comments

 Excellus is asking for a 6.99% rate increase on an already very expensive policy. With a large deductible and copay as
 well. My rate is now $662.00 per month. Seems like a ridiculous request when they pay their top executives in excess
 of $1 million per year. And if you don't grant their request they simply raise my deductible to compensate. Enough is
 enough. Block the increase. Their greed is sickening.

 I disagree with increasing the health insurance premiums. The burden of COVID-19 not only impacted institutions but
 also many families financially and emotionally as well. The cost of health care in the USA is quite outstandingly high
 compare to many other countries. By increasing the premiums, it may cause a ripple effect on the residents of NY.
 Furthermore, not only would they be concerned about paying their monthly premiums, their deductible if something
 happened, and as well as the cost of well-being.. Please reevaluate why the premiums need to increase or change for
 the residents of NY. Please and Thanks.

 Health insurance should be like car insurance - if your health is good and you don't need to go to the doctor frequently,
 you should either get a significant rebate or your annual premium should go DOWN!! Every year my premium increases,
 while I go to the doctor less or NEVER each year, because I practice a healthy lifestyle. This 7% proposed increase for
 next year is so excessive!! We are being punished for the effects of COVID!

 Regarding the EPO HDHP plan with HIOS ID 78124NY0900013-01, which is the Bronze Select plan which Excellus offers
 on the Marketplace in             County: Excellus should not be permitted to increase rates on this plan at all. Excellus
 has repeatedly been forced to disgorge excess premiums due to not meeting the minimum standards for percentage of
 premiums spent on health care. I have now received these refunds for 2015, 2016, and 2017, and I presume I will in due
 course receive them for 2018, 2019, and 2020. It is clear that they have simply been overcharging as a matter of course.
 It is time for them to stop borrowing money from customers by overcharging us on premiums and refunding the money
 five or more years later. Better that they undercharge for a year or two.

 I oppose a rate increase without improved coverage to accompany the extra dollars that I will have to pay. Please
 inform me of how my benefits will change for the better with an increased out-of -pocket cost. I currently am
 undergoing physical therapy after a                        . The therapy is helping the mobility challenges. However,
 approval for the needed treatment lies in the hands of an insurance advocate who knows nothing about my case or how
 I have progressed to date. The insurance company’s ability to limit access to a program necessary for my recovery is just
 one example of what is wrong with the current health care system. A rate increase is not the answer.

Excellus Health Plan, Inc.
Individual
2022 Public Comments

 I received a letter in the mail from Excellus stating that they were seeking a 6.99% rate increase for my 2022 premiums.
 I strongly disagree with the proposed rate increase for various reasons, which I will detail below. A more modest
 increase of 1-1.5% seems more reasonable based on their current financial standing and the projected healthcare costs.
 I read through the long-winded statement by Excellus on their justification of the increase. However, I fail to see their
 point in light of their rather generous compensation packages for top executives, the amount they have in financial
 reserves, the significant cost savings as a result of COVID19 winding down, and the recent settlement of the parent
 company Blue Cross Blue Shield (BCBS) in an antitrust class action lawsuit. I will cover each point in detail, less the first
 point because that is self-explanatory. While some health insurance companies posted record profits during the
 pandemic due to patients delaying care, Excellus suffered a small loss. According to news articles online, their cash
 reserves dropped from 1.4 billion dollars to 1.2 billion dollars (i.e., 200 million dollars), or a 14% decrease. Given the
 unprecedented nature of the COVID19 pandemic, a 200 million dollar loss isn’t too bad. According to Excellus, their
 customer base is about 1.5 million people. On a per person basis, the loss was about $130 per customer. A partial
 breakdown of the 200 million loss was also provided. 102 million dollars (~50% of the loss) went to increased
 telemedicine coverage and provider reimbursement (which to my knowledge ended a few months ago). Additionally, 3
 million went towards increased reimbursement for COVID19 hospital admissions, 1 million in grants to hospitals for
 COVID19 testing supplies and PPE, $250,000 in grants to hospitals for COVID19 testing machines, and 21 million in
 medical and dental premium refund credits to employers and union sponsored plans. The majority of these costs are
 COVID19 related, which by 2022, should be substantially wound down if not completely gone. Regarding litigation, an
 antitrust class action lawsuit was brought against BCBS, and they settled out of court to the tune of 2.67 billion to avoid
 further, and possibly substantially more costly and damaging, litigation. The lawsuit alleged that BCBS “violated antitrust
 laws by entering into an agreement not to compete with each other and to limit competition among themselves in
 selling health insurance and administrative services for health insurance.” If true, which we don’t know because they
 settled out of court, this basically amounts to accusing them of fixing the market at artificially inflated prices to pump up
 profit margins from 2008 to 2020. Basically the entire time the ACA was in effect. Regarding my premiums, I already
 pay $672/month, with a high deductible. A ~7% increase would amount to ~$50/month increase, or roughly $600
 increase for the year. That seems excessive, given their losses were only $130/customer. A 1.5% increase would cover
 those losses. Not to mention, they always raise the deductible each year, which also adds money to their pockets. So,
 this lowers the 1.5% to somewhere between 1 and 1.5%, which is what I suggested above. Also, I find it absolutely
 ludicrous that my health insurance is almost the same as my rent. To summarize, the proposed rate increase is
 excessive and not justified by any of their arguments. If one runs the numbers, a premium rate increase of 1-1.5% would
 be sufficient. The increased costs faced by Excellus this past year were an anomaly, and will no longer be an issue come
 2022. Excellus has substantial financial reserves to cover the minor losses, and I am confident they will continue to
 remain profitable.

 Raising a health insurance premium 6.57% is unacceptable. That is more than twice the cost of living and imposes an
 undue burden on the consumer that is on a fixed income. Wouldn't it make more sense to look at a increase that comes
 in below the cost of living and allows the consumer to keep their chosen insurance instead of having to search for
 another due to this increase. Insurance companies should be more mindful of their members and their needs. And NYS
 should be mindful of what happens when insurance becomes cost prohibitive.

Excellus Health Plan, Inc.
Individual
2022 Public Comments

 I want to strongly urge NYS To deny the rate increase that Excellus BCBS is requesting. If the rates increase, my company
 has indicated that they will stop paying for my health insurance, and I am unable to obtain comparable care on my own.

 I oppose the proposed 11.64% increase in 2022. The escalating premiums are affecting my ability to provide for my
 young family. Our high deductible plan makes it difficult to keep up with healthcare costs, especially while my wife and I
 are expecting our 2nd child. Especially coming off of the heels of a pandemic when many organizations haven't been
 able to increase salaries.

 Raising rates to the common payer is not a solution to cost deficits during a pandemic. Many people have lost jobs
 and/or taken pay cuts during the pandemic. An 11% increase is tone deaf to the struggle of the rest of the country.

Excellus Health Plan, Inc.
Individual
2022 Public Comments

 RE: Requested Rate Changes – Excellus Health Plan – EXHP-132814532 Please see Health Care For All New York's full
 comments on Excellus's rate request here: https://hcfany.org/resources/comments-on-excelluss-2022-rate-request/ II.
 Specific issues in Excellus’s application Excellus is a non-profit EPO with 23,813 members in 2021, down 5% from over
 25,000 in 2019. Its individual market plans serve the Albany, Buffalo, Mid-Hudson, Rochester, Syracuse, and
 Utica/Watertown regions. Excellus projects receiving an 18% subsidy from the federal risk adjustment program in 2022.
 This means that its members are less healthy than average for New York’s individual market and thus incur higher claim
 costs. It is requesting a 6.2% average rate increase for 2022, which is lower than the 10.8% average requested by New
 York’s major individual market plans. Excellus also projects a medical trend of 5.7% for 2022. HCFANY asks that the
 Department review Excellus’ requested surplus, and broker costs before approving this request. Excellus may also be
 able to reduce rate increases by removing a potentially unnecessary increase for Covid-19 costs and adjusting more for
 the impact of increased federal premium subsidies. 1. Excellus’ request for 1.5% surplus should be reduced to 0.5%.
 HCFANY respectfully urges the Department to continue to cap profits for the individual market participants at 0.5%. As
 described above, the pace of New York’s economic recovery is slow. Excellus supported nearly $100 million in net
 income for 2020 and experienced a 30% increase over the prior year. Its fiscal health is so positive that it reported
 issuing premium credits to employers late in 2020. In its individual market business, Excellus’s submissions report that
 it barely maintained the statutory minimum MLR of 82% for 2020 by just .07%. HCFANY estimates that Excellus would
 maintain a reasonable MLR of 87.1% in 2022 if the Department approved a 0.5% surplus and a 12.4% expense ratio.
 Further, Excellus cites reserve requirements when asking to keep 1.5% but does not provide any justification for
 maintaining such enormous reserves. Plans often claim that their proposed surplus is required to maintain healthy
 reserves without providing evidence. HCFANY has long argued that Excellus’ surplus is too large. The Department should
 require Excellus to invest in its members instead of boosting a bloated surplus and large administrative costs. 2.
 Excellus should not use individual market premiums to pay brokers. Excellus reports broker costs of $6.14 per-member,
 per-month. This is too high for the individual market, where the state provides extensive marketing and enrollment
 assistance. New Yorkers can easily research and select individual market plans at nystateofhealth.ny.gov, and those who
 prefer assistance in person can access it in every part of the state. Consumers should not be asked to pay brokers to
 duplicate these services. Moreover, the Actuarial Memorandum does not indicate how many Excellus members in the
 individual market actually use brokers services. Without a detailed description of the number of enrollments facilitated
 by brokers, this adjustment should be disallowed. 3. Though it is requesting a small adjustment for Covid-19 costs
 (0.48%), HCFANY asks the Department to review whether any adjustment is needed for Covid-19 costs in 2022. While
 0.48% is a small adjustment, there were five individual market plans that made no Covid-19 related increase at all
 (Emblem/HIP, Fidelis, Healthfirst, Independent Health, and MetroPlus). Excellus explains in its Actuarial Memo that the
 cost increase it anticipates is related to vaccinations becoming available to children and the possible need for boosters.
 This type of speculation cannot fairly be incorporated into the 2022 rates since it is unclear: (1) that vaccinations will be
 available for children; (2) if and when there will be a need for boosters; and (3) the level of government funding will be
 available to support vaccination efforts. 4. Excellus reduces its request by 1.5% to account for the increased premium
 subsidies that will be available in 2022, but the Department should consider adjusting their rates downward by 6.7% as
 proposed by Emblem. Excellus estimates that the increased federal premium subsidies created by the American Rescue
 Plan will improve its risk pool enough to reduce rates by 1.5%. HCFANY has asked that the Department consider
 imposing a 6.7% rate reduction for all individual market plans to account for this risk pool improvement. Excellus
 provides a helpful explanation for why it may benefit less than other plans from these subsidies. Some plans are more
 likely to directly benefit from increases in enrollment due to the subsidies than Excellus because Excellus is a fairly high-
 cost plan. However, the federal risk adjustment program means that all plans benefit from an improved risk pool, even
 plans that fail to attract new enrollees. Accordingly, HCFANY believes it is reasonable to impose a standard adjustment
 of 6.7% due to increased enrollment related to American Rescue Plan policies. Thank you for your attention.

Excellus Health Plan, Inc.
Individual
2022 Public Comments