July 30, 2015

Bases on which CCM is Asking HHS

to Find the Proposed Rate Increases Unreasonable
1. The insurer disregards the fact that the least healthy people signed up first -i.e., in 2014 -- leaving a healthier group of people to sign up in 2016.
2. The insurer disregards the fact that the minimum penalty for not buying
insurance in 2016 will be substantially greater than it was in the past -- $695/2.5
percent of income v. $325/2 percent of income in 2015 and $95/1 percent of
income in 2014 -- thus creating a much stronger incentive for young healthy
people to sign up.
3. The insurer disregards the fact that for people enrolling in 2014, pent-up
demand -- their getting treatment for conditions they had not gotten treatment
for in the past because they didnt have insurance -- has been fulfilled.
4. The insurer assumes that health care costs will increase at a higher rate than
the data indicate -- i.e., it assumes an unreasonably high trend factor.
5. The insurer includes a risk margin in its rate despite the fact that it is well
protected by the ACAs reinsurance, risk-adjustment and risk corridor programs.
6. Even in the non-redacted version of its actuarial memorandum, the insurer
does not include data that support its estimates and assumptions.