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Indiana Department of Insurance

IDOI > Company Compliance > Accident & Health  > Product Filing Information/Instructions  > 4.2(B) NON-QUALIFIED HEALTH PLANS (NONQHPs) SMALL GROUP RATE REQUIREMENTS for MAJOR MEDICAL and HMO 4.2(B) NON-QUALIFIED HEALTH PLANS (NONQHPs) SMALL GROUP RATE REQUIREMENTS for MAJOR MEDICAL and HMO

NEW RATE and/or FORM

(INCLUDING NON-EMPLOYER ASSOCIATIONS and/or TRUSTS)

The Indiana Department of Insurance (IDOI) requests data/information for the following four requirements as part of the rate review process for new rates and/or forms filed: Implementation Date, Rate Review Detail, Actuarial Memorandum and Rate Summary Worksheet/Unified Rate Review Template.

Data for requirements I and II are entered into SERFF fields.

I. IMPLEMENTATION DATE

  1. Enter the date requested for the filing to be implemented.
    1. Date must be a minimum of 60+ days from the submission date.
    2. Date entered may not be the date the filing officially becomes effective.
      1. IDOI will determine the definitive effective date.
      2. If “Upon Approval” is chosen, the filing will not be closed until this field is revised with an actual date.
    3. If date changes during the review process, the following action is needed:
      1. Update SERFF field before the filing is completed and closed.
        1. SERFF field can be revised during a “Post Submission Update” at the time a response is provided for the objection.

II. RATE REVIEW DETAIL

Located under the Rate/Rule Schedule tab in SERFF.

Reference the SERFF Data Field Guide under section Rate Review Detail to accurately complete the specific SERFF data fields listed below for this requirement. All fields should be state specific.

  1. Complete the following data fields in the Rate Review Detail template:
    1. Company Name
    2. HHS Issuer ID
    3. Product Names
    4. Trend Factors
    5. Forms
      1. New Policy Forms (including form numbers)
    6. Requested Rate
      1. Projected Earned Premium
      2. Projected Incurred Claims
      3. Annual PMPM $: Min, Max and Weighted Average

Accurate reporting will avoid filing errors as related to submitting rate requests and for federal reporting.

III. ACTUARIAL MEMORANDUM

Provide the data listed below in the actuarial memorandum as an attachment under the Supporting Documentation tab in SERFF.

  1. Benefit Structure
    1. Provide sufficient detail for an analysis of the pricing including scope and purpose.
    2. Provide Market Impacted.
    3. Provide a summary of benefits provided for the following:
      1. Essential Health Benefits
      2. State Mandated Benefits
      3. Additional Mandatory Supplemental Benefits
      4. Additional Optional Supplemental Benefits
  2. Proposed Rates
    1. Include a complete set of proposed rates.
    2. Include the following items and any other guidelines that impact policyholder’s premium payment:
      1. Modal factors
      2. Geographic factors
      3. Family size
      4. Tobacco Use Factors
      5. Changes in Morbidity
      6. Additional Mandates
      7. Other Factors
  3. Projected Experience with Enrollment Projections
    (Provide best estimates for the data below.)
    1. Earned Premium
      1. Provide the projected earned premium using realistic assumptions for the following:
        1. Next 12 months
        2. Next full calendar year
        3. Anticipated implementation date
    2. Incurred Claims
      1. Provide the anticipated projected incurred claims using realistic assumptions for the following:
        1. Next 12 months
        2. Next full calendar year
    3. Anticipated Loss Ratios
      1. Provide the anticipated loss ratios for the following:
        1. Next 12 months
        2. Next full calendar year
    4. Projected Federal MLR
  4. Assumptions
    1. Include the following data and a detailed description of the basis for the assumptions used in pricing: (Follow the guidelines from Actuarial Standards of Practice (ASOP) No. 8.) http://www.actuarialstandardsboard.org/pdf/asops/asop008_129.pdf
      1. Annual Overall Trend Rate
        1. Provide the annual per individual rate of medical cost increase assumed for the next year.
        2. Provide the annual per individual rate of premium increase assumed for the next year.
  5. Premium Guarantee Provision
    1. Provide a detailed description of the premium rate guarantee provision.
  6. Rating Factors
    1. Identify from the following which rate structure or any other is used for this product:
      1. Age Factors
      2. Geographic Factors
      3. Tobacco (Rate cannot vary by more than 1.5 to1.)
      4. Family Composition
      5. Benefit Plan Factors
    2. Non-Benefit Expenses
      1. Administrative Expenses
      2. Sales and Marketing Expenses
      3. Net Cost of Private Reinsurance
      4. Premium Tax
      5. Other Taxes, License and Fees
      6. Other Expenses
      7. Risk Margin
      8. Profit or Contribution to Surplus Margin
    3. Impact of Contractual Arrangement
      1. Provide information regarding the expected impact of contractual agreements with health care providers and administrators.
  7. Company Financial Position
    1. Provide information on the company’s financial position.
      1. Include the risk-based capital ratio as of the most recent year-end.

Attestations

  1. Small Group Attestation
    1. Provide an attestation along with documentation confirming the following:
      1. Review of Indiana’s small group health law. (Ind. Code §27-8-15)
      2. Compliance with Indiana’s small group health law. (Ind. Code §27-8-15)
      3. Intent to file annual actuarial certification. (Ind. Code §27-8-15)
  2. Actuarial Certification/Rate Attestation
    1. Provide an actuarial certification with a clear statement attesting to the following:
      1. Compliance with all applicable state and federal statutes and regulations.
      2. Compliance with actuarial standards of practice (ASOP).

IV. RATE SUMMARY WORKSHEET/UNIFIED RATE REVIEW TEMPLATE

Rate Summary Worksheet

In accordance with the Rate Increase Disclosure and Review 45 CFR Part 154 issued by the Department of Health and Human Services, health insurance issuers are required to complete the Rate Summary Worksheet for rate increases in the individual and small group markets that meet or exceed the “subject to review” threshold. The required reporting was effective September 1, 2011. To complete the worksheet, issuers must access the Health Insurance Oversight System (HIOS) and download the most recent Excel template.

The following are Indiana specific reporting requirements for the worksheet:

  • Complete worksheet providing data for ALL rate adjustments in the individual and small group markets, regardless of whether the rate action meets or exceeds the “subject to review” threshold of 10% as stated in the Rate Review Regulation.

  • Complete worksheet providing data for Non-Grandfathered plans.

  • Attach the document via SERFF to the Rate Summary Worksheet Requirement as part of Supporting Documents. Ensure document is properly completed and satisfied.

  • Avoid bypassing the worksheet, unless filing for large group plans or excepted benefits.

  • Attach the same version of the Rate Summary Worksheet completed in HIOS for filings with a rate increase that meet or exceed the “subject to review” threshold of 10%.

  • Upload an amended Rate Summary Worksheet following any changes in HIOS, if applicable, and/or in the rate review process.

  • The worksheet must be attached under the Supporting Documentation tab in SERFF.

The data from the Rate Summary Worksheet will be considered as part of the rate review process. In addition, for those plans that meet or exceed the threshold, the Rate Summary Worksheet will be posted to http://www.healthcare.gov/ as part of a web-based consumer disclosure.

Unified Rate Review Template

The Unified Rate Review Template must be completed and submitted to (HIOS) for all rate increases, above 0%, to comply with the new federal reporting requirements (Part I). This also includes the existing reporting requirement for rate increases that have an Overall % Rate Impact or Weighted Average over the last 12 months that is greater than or equal to the “subject to review” threshold of 10%.

The rate files that meet the “subject to review” threshold of 10% will continue to complete and submit in HIOS a written description (narrative) justifying the rate increase (Part II). This is not required for rate filings that must “just be reported” for increases above 0%.

All rate increases which include the files that must “just be reported” for increases above 0% and that meet the “subject to review” threshold of 10% must complete an actuarial memorandum and attestation (Part III).

The new federal reporting requirements that consist of Parts I, II and III are satisfied by completing and submitting in HIOS the template and narrative, if applicable.

HIOS & Rate Summary Worksheet/Unified Rate Review Template Reporting Guidelines

The following provides additional information to properly complete the Rate Summary Worksheet for the rate files that meet or exceed the 10% threshold:

  • Submit rate file to SERFF and HIOS on the same day.
  • Include SERFF Tracking Number in HIOS at the Filing Tracking Number field.
  • Changes to filing information and/or the Rate Summary Worksheet on HIOS must also be updated in SERFF.
  • Must match Product(s) listed in HIOS with SERFF Product Name and Market Type.

Rate Filing Submittal Guidelines

The following provides additional information to properly submit rate filings:

  • Unless filing approved, do not implement a rate increase as related to manual rates.
  • Unless file approved, do not implement a rate increase as related to trend beyond the implementation date.
  • File proper TOI and Sub-TOI for rate request.
  • Submit the Individual and/or Small Group Market filings, as applicable, by creating a SERFF Binder.  The Binder is part of the new Plan Management enhancement in SERFF for nongrandfathered filings on and/or off the health insurance exchange.
(SERFF allows a maximum of 250 plans per binder per market segment.)