5. That calculation, however, omits the transitional policies in Obamacare that help insurers keep premiums low as the risk pool sorts itself out over the first three years. Add those in, and it's unlikely that 2015 will see any premium increase at all. Robert Laszewski, a consultant for the insurance industry, agrees. "I think the 2015 rates will be the rates youre looking at today, more or less," he says.
I'm not sure I buy point #5 at this time, on a few different fronts:
1. The 2014 loss experience likely won't even be reflected in 2015 rates. Insurers will be developing and submitting 2015 rates in the March-May timeframe. They will have about a quarter of a year of loss data before they get in to the meat of their rate development. How will they be able to accurately reflect 2014 experience into 2015 rates if open enrollment is still ongoing or has just closed? Practically, they will be rating based on marketplace assumptions that could not be accurate.
2. The 2014 transitional programs likely won't be reflected in 2015 rates. 3 R's money for 2014 won't be paid out until mid- to late-2015. Insurers won't know their loss experience until the end of 2014. Rates must be developed early in 2014. Rate filings will have a difficult time justifying the actuarial assumptions used under those circumstance.
3. CCIIO announced that the transitional reinsurance program fee for 2015 was going to decrease to about $45 per person per year (down from about $63 pppy in 2014). However, the White House also announced that self-insured plans not using a third-party administrator would be exempt from the transitional reinsurance fee for 2015. It seems likely that the fee will have to increase to cover the mass exodus of fee-paying lives.
4.
ALL currently-compliant health plans will have to re-price in 2015 owing to CCIIO making changes to the AV calculator. Some of these changes are rather profound, to the point that insurers are worried that existing plans might jump as many as two tiers up or down based on plan design.
Anecdotally, we've been having discussions here about "rate shock #2" in 2015 not about "2015 is more of the same."
That's not to say that there are not some factors that might work to suppress rates in 2015:
1. Many established insurers, especially those in states without true rate review authority, may have been keeping rates artificially low (to the point of being legally inadequate), relying on reserves to bring them through 2014 in a hope of grabbing market share (history shows that individual insurer and plan choice is "sticky"). Since 2014 has had, to date, a disappointing enrollment they might try again in 2015.
2. In states that did not support the President's plan to allow policies purchased or renewed before 10/2/13 to renew again in 2014 the current non-compliant, nongrandfathered market will disappear. This market is generally healthier than the 2014 open enrollment market, so that may depress rates (though in states that allowed early renewals in December the effect may be nonexistent).
That being said the re-emergence of the employer mandate in 2015 could push individual rates higher. There is a school of thought that says self-insured employers, once faced with the mandate, will jettison their worst risks onto the exchanges and pay the resultant fines because it will make their self-insured risk pool much healthier. Given some of the rules around employer coverage (the exemption from the transitional reinsurance plan described above, the fact that offering insurance to all employees actually has a 95% safe-harbor provision) it is theoretically possible that a self-insured employed could dump the unhealthiest 5% into the individual market, face no penalty, and really sour the individual risk pool.