ANNUAL HEALTH INSURANCE RATE FILINGS FACT SHEET FOR FULLY INSURED INDIVIDUAL AND SMALL GROUP PLANS
Disclaimer: This fact sheet applies specifically to the rate review process for individual and small group fully insured health insurance plans offered on and off Connecticut’s health exchange, Access Health CT. It does not apply to self-funded, employer-sponsored plans regulated by the U.S. Department of Labor under ERISA, nor to Medicare Supplement plans.
The Federal Government sets the annual health rate deadline which is why the Connecticut Insurance Department (CID) cannot delay their actuarial rate review and process.
The timeline and deadlines associated with the annual health rate filings and review is not in the exclusive control of CID but instead is within the purview of the federal government through the Centers for Medicare & Medicaid Services’ (CMS) and the Center for Consumer Information and Insurance Oversight (CCIIO), part of the Department of Health & Human Services (DHHS). CMS/CCIO provides national leadership in setting and enforcing standards for health insurance that promote fair and reasonable practices to ensure that affordable, quality health coverage is available to all Americans.
These health insurance rates are for individual and small group plans offered on and off the state exchange Access Health CT. The Connecticut Insurance Department does not regulate self-funded plans which fall under the authority of the U.S. Department of Labor.
On and Off Exchange health plans are annual plans that are rated and expire on an annual basis, primarily during a calendar year, but some Small Group annual plans are not held to the calendar year.
The Annual Filing, Review and Rate Setting Process Runs from January to January
The Rate Review Process and Timeline:
January – CID publishes a bulletin in January of each year with instructions to the carriers on their rate filings effective for the following calendar year. See Bulletin HC-81-24 Health Insurance Rate Filing Submission Guidelines.
Spring – During the spring months the carriers gather data from the prior years’ experience to use in their filing for the following plan year.
June – At the beginning of June, the carriers submit their health rate filings with CID for the next year. As such, CID’s Life & Health (L&H) unit and L&H actuaries review the filings during the summer months and correspond with the carriers regarding any questions they have about the filings. All of the filings and correspondences are publicly available and posted on the CID website at https://www.catalog.state.ct.us/cid/portalApps/RateFilingDefault.aspx
August – CID hosts a public informational meeting with the carriers concerning the filings. The public is invited to participate and submit any comments and testimony. Following the public meeting, CID continues its actuarial review.
September – The Commissioner makes a final decision on the rate filings either approving, modifying, or denying the rate requests.
The determined rates need to be submitted to CMS and AHCT no later than mid-September.
The rates are then posted by CMS and Access Health CT no later than November 1st, the beginning of open enrollment.
November – AHCT anticipates having rates and plans posted on its website at least two weeks before the beginning of open enrollment that begins November 1st. That schedule provides consumers with ample time to review the plan options, and to make a more informed decision on which plan best fit their needs.
December – Before the end of open enrollment on December 15th, consumers make their decision in order to have a health care plan in place by the January 1st effective date of the following calendar year.
January – The new plan goes into effect for the calendar year.
Any disruption or delay in this process or timeline puts in jeopardy whether plans will be filed and made available by the deadlines set by CMS. The result of which could potentially make certain plans not available for the next calendar year reducing consumer options, or alternatively resulting in consumers not having coverage for the following year.
The annual health rate review filings and process are unlike most other rate setting procedures in the state of Connecticut. These health plans are issued on an annual basis and filings of the carriers and process of the Insurance Department must fit within this yearly time-frame and the deadlines set by CMS. As such, any analogy to other insurance plan rate reviews and other rate reviews in the state is unreasonable.