Collection of Rate Data for All Products Providing Health Insurance Coverage that is not Considered an "Excepted Benfit"

COMMISSIONER OF SECURITIES & INSURANCE MONICA J. LINDEEN COMMISSIONER OFFICE OF THE MONT ANA ST ATE AUDITOR ADVISORY MEMORANDUM To: ALL MAJOR MEDICAL HEALTH INSURANCE INSURERS MONICA J. LINDEEN. Com . ioner of Se urities and Insurance, Montana State Auditor March 19, 2012 . /l ~y() Date: From: COLLECTION OF RATE DATA FOR ALL PRODUCTS PROVIDING HEALTH INSURANCE COVERAGE THAT IS NOT CONSIDERED AN "EXCEPTED BENEFIT" This memorandum follows-up on the October 2010 advisory memorandum regarding the collection of rating information for major medical health insurance. The Office of the Commissioner of Securities and Insurance, Montana State Auditor (CSI), must continue to "provide the secretary [of Health and Human Services] with information about trends in premium increases in health insurance coverage in premium rating areas in the State." The purpose of this advisory memorandum is to request health insurance issuers selling health insurance products (that are not "excepted benefits" as defined in Mont. Code Ann. S 33-22-140) in Montana to submit certain rating information for the following two purposes: • To understand and report trends in premium increases in the Montana Health Insurance market; • To continue the review of compliance with existing Montana rating law and rating disclosure laws for all health insurance issuers doing business in Montana and described in the 2010 memorandum. Phone: 1-800-332-6148/ (406) 444-2040/ Main Fax: (406) 444-3497 Securities Fax: (406) 444-5558/ PHS Fax: (406) 444-1980/ Legal Fax: (406) 444-3499 840 Helena Ave., Helena MT 59601 Website: www.csLmt.gov E-Mail: csi@mt.gov review of compliance with existing Montana rating law and rating disclosure laws for all health insurance issuers doing business in Montana and described in the 2010 memorandum. Phone: 1-800-332-6148/ (406) 444-2040/ Main Fax: (406) 444-3497 Securities Fax: (406) 444-5558/ PHS Fax: (406) 444-1980/ Legal Fax: (406) 444-3499 840 Helena Ave., Helena MT 59601 Website: www.csLmt.gov E-Mail: csi@mt.gov At this time, the CSI is requesting updated rating information on 2012 rate increases in order to keep its information about premium trends in Montana current. In addition, this information will assist the Commissioner in determining whether or not to recommend to the secretary a change in the 10 percent state-specific threshold triggering federal rate review under 45 CFR part 154 after September 2012. The CSI will not use the "Rate Data Disclosure Form" that was referenced in the 2010 advisory memorandum. That form is deleted from the CSI's SERFF reporting page. CSI is posting new, simplified reporting instructions on its SERFF web page and reduced information is being requested. A print-out of the information being requested in SERFF is attached to this memo. This request applies to all rate increases implemented anytime during the 2012 calendar in the major medical individual, small employer group, and association markets. Large employer groups that do not consist of bona fide association members are exempt from this data request. Please supply the corresponding 2012 rate manual. Include a brief memo of changes made to the rating methodology and/or manual from the prior version submitted. If your rating manual is identical to the rating manual submitted in 2011, please note that fact. Please submit all rate increases that have already been implemented for 2012 through the SERFF system no later than April 30, 2012. Information concerning additional rate increases that are implemented after that date during 2012 should be submitted as new filings in SERFF the prior version submitted. If your rating manual is identical to the rating manual submitted in 2011, please note that fact. Please submit all rate increases that have already been implemented for 2012 through the SERFF system no later than April 30, 2012. Information concerning additional rate increases that are implemented after that date during 2012 should be submitted as new filings in SERFF. The CSI is collecting this information pursuant to its authority to examine and investigate under Mont. Code Ann. 933-1-314. Thank you for your cooperation in this matter. If you have comments or questions, please call or email Christina Goe, General Counsel at 406-444-2040 or cgoe@mt.gov. 2 Montana Collection of Rate Data 2012 Required SERFFFields Important Information for All Filers Read this entire document carefully - it contains new information and Montana-specific requirements. All information should reflect only the specific product for which these rates are filed and be provided at a company level for Montana business only. Responses based on national, combined holding company, or entire line-of-businesss information will not be accepted. For association business written in Montana, separate filings must be submitted for each association. General Information tab Field Required by Montana Comments Product Name SERFF/ HHS Please use an aoorooriate name. Include the association name for association business. Tal SERFF/ HHS In general, it is anticipated that all filings should be coded as Major Medical, either H161 for Sub-Tal SERFF/ HHS individual, or H16G for group. If you feel that a different Tal is more appropriate, please contact us in advance to confirm. Filin!! TVDe SERFF/ HHS All filings should be coded as "Rate." Implementation Date SERFF/ HHS Please specify that actual intended implementation date. Please do not code as "On Requested Approval" - this response is not applicable. For filings with multiple effective dates, please reflect the earliest date you feel that a different Tal is more appropriate, please contact us in advance to confirm. Filin!! TVDe SERFF/ HHS All filings should be coded as "Rate." Implementation Date SERFF/ HHS Please specify that actual intended implementation date. Please do not code as "On Requested Approval" - this response is not applicable. For filings with multiple effective dates, please reflect the earliest date. PPACA SERFF/ HHS Any response will be accepted, however, "Not PPACA-Related" is preferred. Requested Filing SERFF/ HHS Any response will be accepted, however, "Informational" is preferred. Mode Market Tvoe SERFF/ HHS Please see Market Type Table below. Individual Market SERFF/ HHS The visibility of this field depends upon the response to Market Type. Please see Market Type Type Table below. Group Market Size SERFF/ HHS The visibility of this field depends upon the response to Market Type. Please see Market Type Table below. Group Market Type SERFF/ HHS The visibility of this field depends upon the response to Market Type. Please see Market Type Table below. Filin!! DescriDtion SERFF/ HHS Please provide an applicable descriotion of the filing. Market Type Table Description Market Type Individual Market Type Group Market Size Group Market Type Pure individual Individual Individual NA NA Association issued to Individual Non Employer Group - NA NA individuals Individual Single employer Group NA Enter "Small" - the data Employer group collection request does not Association issued to Group NA cover large group. Include Association only information for small employers employers. 3/19/2012 Page 1 of 4 Leif Associates, Inc e Group Market Type Pure individual Individual Individual NA NA Association issued to Individual Non Employer Group - NA NA individuals Individual Single employer Group NA Enter "Small" - the data Employer group collection request does not Association issued to Group NA cover large group. Include Association only information for small employers employers. 3/19/2012 Page 1 of 4 Leif Associates, Inc Rate / Rule Schedule tab Montana Collection of Rate Data 2012 Required SERFF Fields Field ReQuired bv Montana Comments Company Rate SERFF/ HHS Please select an appropriate response - Increase, Decrease or Neutral. Change? Overall % Rate Impact Montana Please provide the premium weighted average rate impact as a result of all changes represented in this filing for the business expected to be in force as of the implementation date. Written Premium Montana Please provide the premium dollar impact as a result of all changes represented in this filing Change for this for the business expected to be in force as of the implementation date. Program # of Policy Holders Montana Please provide the number of policy holders for the business expected to be in force as of Affected for this the implementation date. For group business, please provide the number of Program subscribers/employees rather than the number of employers (note - this differs from the HHS definition of policy holders for the field below). Written Premium for Montana Please provide the annualized premium dollars for the business expected to be in force as of this Program the implementation date prior to the impact of the changes represented in the filing. Maximum % Change Montana Please provide the maximum possible rate impact combined for all changes represented in the filing, regardless of actual business in force. Note - this differs from the HHS definition of maximum rate change as defined below in the View Rate Review Detail table in force as of this Program the implementation date prior to the impact of the changes represented in the filing. Maximum % Change Montana Please provide the maximum possible rate impact combined for all changes represented in the filing, regardless of actual business in force. Note - this differs from the HHS definition of maximum rate change as defined below in the View Rate Review Detail table. Minimum % Change Montana Please provide the minimum possible rate impact combined for all changes represented in the filing, regardless of actual business in force. Note - this differs from the HHS definition of minimum rate change as defined below in the View Rate Review Detail table. View Rate Review SERFF/ HHS All fields are required. Please refer to the View Rate Review Detail table for a complete Detail description. Number of Policy SERFF/ HHS Count each policy only once using the most specific Product Type. Please refer to SERFF Holders help (? Button) for descriptions of the Product Types. For single employer group business, count the group policy holders - the employers, not the certificate holders - the employees. For employers offering more than one Product Type, count them under the most prevalent one chosen according to current in force. For association business, count the number of employers for group business and the number subscribers for individual business. Number of Covered SERFF/ HHS Count each life only once using the most specific Product Type. Please refer to SERFFhelp (? Lives Button) for descriptions of the Product Types. Affected Form Montana Please provide a listing of the policy form numbers affected by this filing. All form numbers Numbers must be listed individually and separated by commas. Document Name SERFF/ HHS Please orovide a general description of the attached rate manual. Rate Action SERFF/ HHS Please select "Revised" for a rate change on an existing product or "New" for an initial filing of rates for a new product Montana Please provide a listing of the policy form numbers affected by this filing. All form numbers Numbers must be listed individually and separated by commas. Document Name SERFF/ HHS Please orovide a general description of the attached rate manual. Rate Action SERFF/ HHS Please select "Revised" for a rate change on an existing product or "New" for an initial filing of rates for a new product. We do not anticipate "Other" to be an appropriate response, if you disagree, please contact us. Attach Document Montana Please attach your rate manual here. For purposes of this request, an official rate manual is not needed, but the provided document(s) needs to provide everything necessary to calculate all offered rates, e.g. - factor tables, rating algorithm, rider rate tables, renewal methodology, etc. For rate revisions, please clearly indicate all changes from the previously submitted manual. 3/19/2012 Page 2 of 4 Leif Associates, Inc Montana Collection of Rate Data 2012 Required SERFFFields View Rate Review Detail. Page 1 of 2 Field Required bv Montana Comments Comoanv Name SERFF/ HHS Please enter the comoanv name. HHS Issuer ID SERFF/ HHS This is a five digit code issued by the HHS HIOS system. Issuers who have submitted data for display on HealthCare.gov have obtained their 10 from the HIOS system. For those issuers who have not yet submitted data into HIOS or have not yet received their 10, please enter '00000'. Product Names SERFF/ HHS The 'street' name of the insurance oroduct as sold by the insurance comoany. Trend Factors SERFF/ HHS Text description of trend factors and rating factors used in developing the rate as implemented under the allowed filing requirements and restrictions in that state. FORMS New Policy Forms SERFF/ HHS At least one of the three Form categories must be completed with a form name or number. All form names or numbers must be listed individually and separated by commas. Please do not enter 'None' or 'N/A' in any field n of trend factors and rating factors used in developing the rate as implemented under the allowed filing requirements and restrictions in that state. FORMS New Policy Forms SERFF/ HHS At least one of the three Form categories must be completed with a form name or number. All form names or numbers must be listed individually and separated by commas. Please do not enter 'None' or 'N/A' in any field. Each affected form on this filing should be listed in one of the following categories: Affected Forms for SERFF/ HHS Closed Blocks New Policy Forms: This field should contain those forms for which rates have not been previously submitted. Other Affected Forms SERFF/ HHS Affected Forms for Closed Blocks: This field should contain those forms currently part of a closed block of business. Other Affected Forms: This field should contain all other forms that do not qualify for the previous field categories. REQUESTED RATE CHANGE INFORMATION Change Period SERFF/ HHS Please select an appropriate response. Annual, Semi-annual, Quarterly, or Other. If there are multiple change periods on products within a filing, the filer should select "other" . If an increase is for a calendar year or effective for an elapsed year's time from effective date of the increase one should use 'annual'. If the rates reflect rolling increases on say a quarterly basis, but they are implemented to a given policyholder on a cumulative basis upon their anniversary it is called 'quarterly'. Member Months SERFF/ HHS The member months used for the purpose of the rate development for the products represented in this filing. If a company files more than one rate change in a single filing, the member months will be the aggregate sum of the 2 (or more) rate changes. The number of member months reported should reflect the number of member months used for the experience period of the rate development. Benefit Change SERFF/ HHS Please select an appropriate response -Increase, Decrease or None ts represented in this filing. If a company files more than one rate change in a single filing, the member months will be the aggregate sum of the 2 (or more) rate changes. The number of member months reported should reflect the number of member months used for the experience period of the rate development. Benefit Change SERFF/ HHS Please select an appropriate response -Increase, Decrease or None. Percent Change SERFF/ HHS Please provide the percentage rate change requested in the filing. Requested The average should be weighted using premiums. The minimum and maximum should reflect the least and greatest rate change expected to impact actual policy holders currently in force. 3/19/2012 Page 3 of 4 Leif Associates, Inc Montana Collection of Rate Data 2012 Required SERFF Fields View Rate Review Detail - Page 2 of 2 Field Reauired bv Montana Comments PRIOR RATE Total Earned SERFF/ HHS The total premium dollars expected to be collected over the one year period that ends with Premium the effective date for the proposed premium rates. Projections should be based upon the population currently in force - assume no issues, terminations, plan migrations, or option changes. Do, however, reflect all automatic changes in rates for items such as age or trend. Total Incurred Claims SERFF/ HHS Total Projected Incurred Claims are the Total Incurred Claims for the one year period that ends with the effective date for the proposed premium rates. This may include projected incurred-but-not-reported claims for said period. Projections should be based upon the population currently in force - assume no issues, terminations, plan migrations, or option changes. Do, however, reflect all automatic changes in rates for items such as age or trend. Annual PM PM $ SERFF/ HHS The dollar amount of the Prior Annual Rate on a per-member-per-month (PM PM) basis calculated by subscriber over the one year period that ends with the effective date for the proposed premium rates. The average should be weighted using member months ons, plan migrations, or option changes. Do, however, reflect all automatic changes in rates for items such as age or trend. Annual PM PM $ SERFF/ HHS The dollar amount of the Prior Annual Rate on a per-member-per-month (PM PM) basis calculated by subscriber over the one year period that ends with the effective date for the proposed premium rates. The average should be weighted using member months. The minimum and maximum should reflect the least and greatest subscriber-level PMPM (or family-level, if applicable) expected over the one year period. Projections should be based upon the population currently in force - assume no issues, terminations, plan migrations, or option changes. Do, however, reflect all automatic changes in rates for items such as age or trend. REQUESTED RATE Total Earned SERFF/ HHS The total premium dollars projected over the one year period that begins with the effective Premium date for the proposed premium rates reflecting the rates proposed in this filing. Projections should be based upon the population currently in force - assume no issues, terminations, plan migrations, or option changes. Do, however, reflect all automatic changes in rates for items such as age or trend. Total Incurred Claims SERFF/ HHS Total Projected Incurred Claims are the Total Incurred Claims projected for the current one year period under the new rate structure that begins with the effective date for the proposed premium rates. Projections should be based upon the population currently in force - assume no issues, terminations, plan migrations, or option changes. Do, however, reflect all automatic changes in rates for items such as age or trend. Annual PM PM $ SERFF/ HHS The dollar amount of the Requested Annual Rate on a per-member-per-month (PM PM) basis calculated by subscriber over the one year period that begins with the effective date for the proposed premium rates. The average should be weighted using member months lan migrations, or option changes. Do, however, reflect all automatic changes in rates for items such as age or trend. Annual PM PM $ SERFF/ HHS The dollar amount of the Requested Annual Rate on a per-member-per-month (PM PM) basis calculated by subscriber over the one year period that begins with the effective date for the proposed premium rates. The average should be weighted using member months. The minimum and maximum should reflect the least and greatest subscriber-level PM PM (or family-level, if applicable) expected over the one year period. Projections should be based upon the population currently in force - assume no issues, terminations, plan migrations, or option changes. Do, however, reflect all automatic changes in rates for items such as age or trend. 3/19/2012 Page 4 of 4 Leif Associates, Inc Brian Seremet Assistant Actuary Assurant Health 55J2 501 W Michigan St Milwaukee, WI 53201 brian.seremet@assurant.com Barbra E. Zess Director, Actuarial Blue Cross/Blue Shield of MT 404 Fuller Ave PO Box 4309 Helena, MT 59604 Aurora Loaiza Senior Contract Analyst Celtic Insurance Company Sears Tower 233 South Wacker Drive, Suite 700 Chicago, IL 60606 aloa iza@celtic-net.com Brenda Dawson Authorized Representative Companion Life Insurance Company 3925 East State Street, Suite 200 Rockford, IL 61108 Brendadawson@inscompliance.com Xiaolu Mu Coffey Director & Actuary HealthMarkets 9151 Boulevard 26 North Richland Hills, TX 76180 lulu .coffey@healthmarkets.com Mark Florian Associate Actuary PacificSource Health Plans PO Box 7068 Eugene, OR 97401-0068 mflorian@pacificsource.com John W. Wiklund VP & Actuary Trustmark Insurance Co 400 Field Drive Lake Forest, IL 60045 jwiklu nd@trustmarkins.com Tom P. Kennedy Assistant VP and Actuary USHEAL TH Group Inc 3100 Burnett Plaza 801 Cherry Street Unit 33 Fort Worth, TX 76102 kennedyt@ushealthgroup.com Tina Thomas Compliance Manager WMI Mutual Insurance Company PO Box 572450 Murray, UT 84157 tinat@wmimutual.com n@pacificsource.com John W. Wiklund VP & Actuary Trustmark Insurance Co 400 Field Drive Lake Forest, IL 60045 jwiklu nd@trustmarkins.com Tom P. Kennedy Assistant VP and Actuary USHEAL TH Group Inc 3100 Burnett Plaza 801 Cherry Street Unit 33 Fort Worth, TX 76102 kennedyt@ushealthgroup.com Tina Thomas Compliance Manager WMI Mutual Insurance Company PO Box 572450 Murray, UT 84157 tinat@wmimutual.com Dick Visser Allegiance Life & Health Insurance Company, Inc. PO Box 3507 Missoula, MT 59806-3507 Todd Lovshin Allegiance Life & Health Insurance Company, Inc. PO Box 3507 Missoula, MT 59806-3507 Mike Frank Blue Cross and Blue Shield of Montana, Inc. PO Box 4309 Helena, MT 59604 Frank Cote Blue Cross and Blue Shield of Montana, Inc. PO Box 4309 Helena, MT 59604 Director of Compliance Companion Life Insurance Company PO Box 100102 Columbia, SC 29202-3102 AnaLisa Robledo, Business Analyst, Regulatory Affairs Corporate Compliance Mega Life and Health Insurance Company Mid-West National Insurance Company of Tennessee 9151 Boulevard 26 North Richland, TX 76180 Bernard Rabinowitz Senior VP- Chief Actuary National Foundation Life Insurance Company 801 Cherry Street, Unit 33 Fort Worth, TX 76102 Jim Gravette PacificSource Health Plans PO Box 7068 Eugene, OR 97401-0068 Julia Hix Time Insurance Company PO Box 3050 Milwaukee, WI 53201-3050 Director of Compliance Celtic Insurance Company 233 S Wacker Dr., Ste. 700 Chicago, IL 60606-6393