Healthfirst PHSP, Inc.Individual2019 Public Comments

Good afternoon, I received a notification from my health insurance company, Healthfirst PHSP, Inc. of a proposed rate change submitted to DFS. In this letter, Healthfirst states that my family's health insurance premiums will rise 21% as of January 1, 2019. I feel compelled to exercise my privilege to comment on this request, as an increase in our premium will significantly impact the financial state of our household. While I understand that an annual/periodic increase to premiums is fair and normal, the amount of increase to our premiums is not commensurate with our income, nor is it a reasonable amount of increase. In 2017, my contribution to our Healthfirst plan (identical to the plan we have now) for two adults (my husband and I) was $777.92, with a state subsidy that amounted to a total monthly premium of $1,065.78. In 2018, our income no longer fell into a bracket that deemed us eligible for the subsidy, so between the loss of this subsidy, and the percentage increase to our premium plan, my husband and I saw a 37% rise in our health insurance expenses for just the two of us (not inclusive of the insurance premium we contribute to our children's separate health plan). Currently in 2018, our monthly premium is $1,223.22. With the proposed 21% increase, this premium would become $1,480.10. This is not affordable to my family, who is already struggling to meet the exorbitant healthcare premium costs (in addition to standard deductibles, out-of-network costs, and co-pays) billed to us. While I understand that Healthfirst is a company that needs to make premium increases from time to time, a 21% jump in rates is not reasonable for one year's time. With increases occurring like this one year after the next, where does it end? Can we expect our premium to double in the next 5 years? As you evaluate this request from Healthfirst, I ask you to consider the standard rate of cost of living increases in 2018, which was 2%. Families all over the country are drowning in this exorbitant contribution to their insurance policies, ourselves included, while our income does not reflect an increase anywhere remotely close to the 21% that Healthfirst is seeking. In this matter, I ask for a sensible compromise, where the increase granted to Healthfirst reflects a reasonable percentage, in line with the cost of living for the individuals enrolled in this plan. As this matter continues to get out of hand with each passing year, we need to ask ourselves, when have we gone too far? I can tell you, as the person struggling to pay for this coverage, that time is here. Please don't make it harder for families to care for one another, so we can focus on raising healthy, nourished, and educated children who are the voices of tomorrow. Thank you.

I am strongly against granting HealthFirst a premium increase. They are taking advantage of consumers, by not paying, delaying paying and incompetent handling of claims.

A 21% increase in too high. How is a person supposed to stay ahead in this world. When employees are getting, at best 3% increases per year, then how can every company rack up insane profits. Please don't allow this insane hike.

Please I can not afford to pay these premiums. I am a temporary worker I am years of age again it is going up every year it does not go up $20.00 it goes up $90-$100.00 dollars. please think about the people that can not afford this or make a policy for people that will work, this is suppose to be for low income people and you become that when you keep bring up these premiums. I appose this increase and will have to go to city hospitals next year.

Healthfirst PHSP, Inc.Individual2019 Public Comments

Just got letter of proposed Health First health insurance increase...21%... from $767 to $928 a month due to cost increases and loss of individual mandate...of course increase was 27% with individual mandate from last year....I wonder how long this madness can go on ...am getting crushed by 15-20% increases every year....If this continued at 15% increases a year I would be paying $35,000 for a year of health insurance at years old..... Just dont know what to do anymore...

I am absolutely appalled that Health First is seeking to raise my premium by 21%. I am already paying $1100/month for health insurance to cover me and my son as a single mom, On my Health First Plan, I have had great difficulty finding any acceptable doctor even paying these exorbitant costs. I will no longer be able to afford this insurance at the new rate and will have to switch my plan. I have a HealthFirst Platinum Leaf Premier insurance. My HIOS ID number is 91237NY0020058. The health system is very broken - care is terrible, doctors are like pimps for the pharmaceutical companies, hospitals are overcrowded. I don't know where all this money goes - to insurance companies, I suspect - but it is clearly not to providing quality health care.

I only use my insurance once a year for wellness visits and once every two to three years for visits. Please do not raise my premium. It's not fair to the average worker. Thank you!

My husband and I pay $893.58 per month for this plan, amounting to $10,722.96 per year. On top of our monthly payments there is an out of pocket of $14,300 per year. I've needed to see doctors this year and the health insurance has not had to pay out much yet since everything is going to my deductible and coinsurance. A 6% increase is another hit to my pocket, adding an additional $643.37 per year to my costs. I do not qualify for any financial assistance, and I cannot see how I am supposed to continue to pay my other bills when Healthfirst is asking me to pay even more to be covered. I do need health insurance, I see doctors, but this increase is too much, considering the out of pocket cost to the insured on top of the monthly premium payments. I do not believe there is enough evidence to support this increase of financial burden on the insured like myself.

The 15% rate increase is absolutely untenable. The co-pays and high deductables already render this policy of very limited value. To increase the premium by 15% is truly beyond the pale and frankly will bankrupt countless families. If increases like this pass, the consequences will be devastating for a large number of New York families. I urge you to reconsider your increase.

Healthfirst PHSP, Inc.Individual2019 Public Comments

This premium plan is already expensive for what i am paying for. Any further increase will create more hardship on my family and I. This plan helps and covers all of my medical needs. I appreciate if you can reconsider or even reduce this monthly cost for me. We are a family of and i have one child that is going to college so any increase will create hardship for us. I really appreciate you taking your time to hear me out. I hope this helped to make your decision.

I received a notice yesterday, June 12 2018, that Healthfirst plans to raise premiums by 21%. This is an extraordinary and outrageous increase. I currently pay nearly $1100 per month for me and minor children. The idea of this going up by nearly a quarter, to $1315 a month, is staggering and should be blocked by DFS. For those in my position --currently single income family but unable to receive subsidies -- this is untenable. I will not be able to afford this.

My current insurance is Healthfirst PHSP, Inc. The plan name is Healthfirst Platinum Leaf. My HIOS Id: number is 91237ny0020015 . I am currenlty paying monthly $768.00 a month and if a 21% increase goes into effect on January 1, 2019 this will increase my payment by $161.28 more a month to a monthly payment of $929.28. I feel very strongly that this increase will make it very difficult for me to continue with my insurance payments. I am just barely making the current monthly payment. Medical insurance increases like this 21% are hurting indivduals to continue meeting there medical payments. I hope that the New York State Department of Financial Services does not approve this increase and realize that it puts a tremendous burden on all of us. Please do not approve this increase. Thank You

I would like to know, why are you letting the insurance rates go up so much every year. It is becoming unaffordable for the average working person. The poor people have better Health insurance then the working person. Something is very work

With rates increasing 20% last year, I don't see how rates could increase 21% they've requested. As a small business owner, I could never stay in business raising my rates at that level. They have a ton of efficiencies that should be possible, especially improved billing. They need to improve their business processes before passing on costs to us consumers!

I have a Healthfirst Bronze Leaf plan, and was informed they are proposing a premium increase starting next year. The rate was already increased from 2017 to 2018 and the coverage isn't even that great. My who I have to see every year, doesn't accept this plan and I have to pay hundreds of dollars out of pocket to see her. I'm a single woman who works for and supports herself and can barely afford this plan as it is. I don't see any reason why I should be charged more when I'm not seeing any increased benefits.

Healthfirst PHSP, Inc.Individual2019 Public Comments

My HIOS identification number is 91237NY0020054. With the implementation of the new health care policies, several employers have opted not to offer a corporate plan and instead allow us to use plans like Healthfirst's. As my income incurs a higher and higher rate of premium, they refuse to reimburse us for the exorbitant increases each year and these come out of our pocket. Additionally, these are not even plans that include very much, so I'm forced to pay out of pocket for all of the preventive care (such as check-ups, cleanings normally covered visits) which increases my costs even more so. I absolutely do not believe that these companies should be allowed to increase premiums even further, as they are already collecting ~600 dollars a month for me and refuse to cover basic preventive care services, let alone actual health issues that may arise. If anything, these rates should be lowered and coverage should be increased.

The premiums/healthfirst Silver Leaf Premier plan do not cover preventative care such as an gynecologist and dental, what's considered basic healthcare. As a healthy person I never reach the deductible of $2670, and end up paying out of pocket for these basic preventative care. It does not make sense for them to raise the premium if they don't at the minimum cover gynecologist preventative care which is a basic human right. How can they raise the cost and not offer a better service? (Its capital greed) Please do not approve the requested rate change. Thank you!

The insurance premium increase should be in line with cost-of-living, around 2%. See the following link: https://www.ssa.gov/cola/ A 21% increase it way too much for my current earning- I may not be able to afford my current plan if it increases 21%.

A 21% increase?? Really now? Our premium is already higher than our mortgage for two adults and kids! This insanity has to stop!

Hello, I am already suffering with the high premium. I totally oppose this proposed premium rate change. If I have to pay more for the insurance premium then I have to cancel the health insurance for me and my family. So please consider not to pass this proposal at any cost. Thanks

Healthfirst PHSP, Inc.Individual2019 Public Comments

I urge you to reject the unreasonable increase of 21% in the premium rate requested by my insurance company for 2019. As a self-employed worker, my income rate is never guaranteed so the stress of making enough to pay for healthcare is always an issue. When the rates went up, as it did every year over the past few years, I was forced to take plans that did not provide the same coverage and decreased the amount of healthcare and preventative care that I might have otherwise received. Needless to say, the insurance companies continue to make a profit so any increase is basically an unreasonable request, brought on by corporate greed and exacerbated by the dictatorship that ruled against the individual mandate. Until a single-payer plan is implemented (as it is in every other civilized country) healthcare costs to individuals such as myself will continue to cause stress on a regular basis -- we will be forced to choose plans that are less expensive but that don't cover our medical needs (and, as you know, medical bills are the primary cause of US bankruptcies). The premium doesn’t even represent all the medical costs – deductibles and co-pays continue to drain additional money saved – money that could help pay for rent, food, and retirement. In the past year, I have already had to change all but one of my specialist doctors to accommodate my new insurance policy. An increase at the requested rate will require me to change to a cheaper plan and change my doctors yet again as I may not be be able to pay that much per month. I also am paying out of pocket for some doctors since the quality of those on my current plan are sub-standard. Please DO NOT increase the premium rates yet again as they are already exorbitant and I am paying out-of-pocket for much of my medical care. I was hoping to continue paying for a long-term care insurance policy as well as disability insurance and other expenses that have kept the insurance companies more than solvent. However, an increase of this magnitude could force me to cancel at least one of these other policies. Please DO THE RIGHT THING - DO NOT AGREE TO THIS INCREASE, and, instead, support the self-employed, like myself, who contribute a great deal already to the pockets of the corporate executives of the insurance companies. Thank you.

After receiving a letter from Healthfirst making me aware of a 15% price increase request to the DFS, Im looking to comment or state that the DFS should deny this request. As almost each year they increase prices with no benefit to their customers.

A 15% increase is unconscionable. Passing the cost on to the consumer is the easiest way to maintain a high-level profit while not controlling the medical or insurance industry cost. For me, 15% equates to an $85 monthly increase. I can't afford this. Now I will have to reconsider my healthcare options. I selected Healthfirst because I thought the costs and services provided were reasonable, but not with such a large increase. Healthfirst needs to control their costs as well. I can certainly understand a 2 -3% increase, but 15% is too much. Please reconsider.

I am writing to complain about the proposed rate increase for 2019, which stands to increase my monthly premium from $611.61/mo. to $740.04/mo. My monthly premiums increased over 20% from 2017 to 2018 so that represents over a 40% increase over the last two years. This runs counter to the vision for the Affordable Care Act and will undermine mine and other individuals' ability to meet necessary expenses. Please let me know what I can do to challenge this increase as it will severely undermine my ability to meet my monthly expenses and I would prefer to have coverage rather than risk not having it.

Healthfirst PHSP, Inc.Individual2019 Public Comments

I a very upset about the rate increase. I can barely pay the premium as it is.

I find it difficult to believe that medical costs have increased 21% in one year, and that Healthfirst is reacting more to the repeal of the tax penalty . They must realize that with that repeal, more insured will opt out of the high cost on health insurance, but with increases like this, they ensure more insured will opt out of being insured. My wife's plan increased 22% this year, from a premium ot $533 to $650. If this increase is approved, her premium will go to $754 according to Healthfirst, and my total outlay for health insurance will increase to $1237 per month, assuming the other premiums I must pay for don't go up. As I am retired, I also may have to opt out of having a policy for my wife, and pay as we go.

NO RATE INCREASE...They already cover almost nothing...I pay $970.00 per mth and then another $1800.00 deductibles and any and a % of each bills that submitted to Healthfirst.

-----Original Message----- From: Sent: Friday, June 15, 2018 8:08 AM To: Subject: NYS Department of Financial Services Consumer Assistance Unit Inquiry Dear : Your inquiry submitted to the NYS Department of Financial Services Consumer Assistance Unit has been received and will be reviewed promptly. The information you entered is as follows: Your Name: Email: Address: Your Company/Organization: Daytime Telephone#: You are a(n): CONSUMER Type of Insurance question/comment: HEALTH Your Questions and/or Comments have been recorded as follows: * * * * * * * * * * * * * * * * * * * * * * * * * I am writing to find out the correct procedure to appeal Healthfirst???s rate increase request for 2019. Healthfirst raised the rates last year and my premiums are over $700/month. While I am happy with the plan [Healthfirst Platinum Leaf Premier], it is becoming increasingly difficult to pay these premiums as a retired Thank you. * * * * * * * * * * * * * * * * * * * * * * * * * Sincerely, New York State Department of Financial Services Consumer Assistance Unit. email at: consumers@dfs.ny.gov

Please do not approve this premium rate change. It is already difficult to pay the monthly premiums while living in NYC and the thought of my premium increasing by that much again is extremely stressful.

Healthfirst PHSP, Inc.Individual2019 Public Comments

I a participant in the Healthfirst PHSP Inc where I have the gold leaf plan. I have individual coverage. I disagree with the price increase. I believe that the main hospital/doctors providing service to this plan are associated with

which has a split billing practice. I think Health First should identify methods to reduce health care chargesincluding 1) providing or motivating improved transparency for hospital and in-office charges to customers (including against competitor groups) 2) requiring hospital and medical groups to provide estimates or ranges of medical charges to customers PRIOR to appointments so that customers can better manage costs and obtain better value for service 3) challenge doctor groups that split billing which obscures the TOTAL medical fees 4) not forming agreements with hospitals for illogical contractual balances that EXCEED the facility or medical charges at the hospital level (reimbursement rates from health first exceed incurred charges!) . The latter provides a back door method for hospitals to earn more than standard costs. Overall more needs to be done by all parties to ensure that medial and health care costs are reasonable. I would like the audited financial statements of medical groups, hospitals etc be made public so the customers have a better idea of profit margins. A number of hospitals in NY are expanding significantly. I believe that the reimbursement fee practices are leading to excess profits to hospitals facilitated and coordinated by the health insurance companies.

Being new to this company and only signing up this year, to have a rate increase for a new member, is very frustrating. I am already paying a lot for minimal coverage( 446.79). I have a 4,000 deductible and even after that is met, I still have to pay 50% out of pocket. To have a 6% increase will my monthly payment by 26.81. Honestly, I do not understand their reasoning. Cost increases for use of expensive specialty prescriptions??? Why is this my fault? The repeal of the tax penalty? So basically, now that people do not have to sign up for health insurance(forced) they do not have as much money coming in? Very sad this is where this company focusing on getting more money to run their business. Us, the consumers who do not abuse the system or take advantage of these reasonings they list. Thank you for allowing our small voices to be heard. Hopefully, some one hears us and will stand up to these insurance giants!

Unknown Insurer2019 Public Comments

-----Original Message----- From: Insurance Inquiry Sent: Friday, June 08, 2018 9:42 AM To: Subject: NYS Department of Financial Services Consumer Assistance Unit Inquiry : Your inquiry submitted to the NYS Department of Financial Services Consumer Assistance Unit has been received and will be reviewed promptly. The information you entered is as follows: Your Name: Email:

Your Company/Organization: Daytime Telephone#: You are a(n): CONSUMER Type of Insurance question/comment: HEALTH Your Questions and/or Comments have been recorded as follows: * * * * * * * * * * * * * * * * * * * * * * * * * Why do health insurance costs go up every year without fail? And why do you use obfuscating language in your increase notice. "Modify"! "Change"! oh please! This is a shameful racket and anyone- anyone who plays a part in it should be ashamed of themselves. Wake up and be human! * * * * * * * * * * * * * * * * * * * * * * * * * Sincerely, New York State Department of Financial Services Consumer Assistance Unit. email at: consumers@dfs.ny.gov

Healthfirst PHSP, Inc.Individual2019 Public Comments

I strongly urge the DFS reject the proposed premium rate change of 15% requested by Healthfirst PHSP, Inc. As a Healthfirst Silver Leaf Premier Member with individual coverage, I receive very little value for what is already an overpriced plan with a high deductible. Indeed, the deductible is high enough that I'm continually paying out of pocket for health services, and, barring catastrophic circumstances, will continue to do so. As such, I'm paying Healthfirst a premium in order to pay for health services, which makes very little sense. Whatever their purported justification for wanting to raise their rates, the reality is they are not providing enough consumer value to do so. The reality is, like all businesses, their bottom line is profit, not the people whose money they take. They will come up with any number of reasons for a rate hike, but it comes down to wanting a higher profit margin, and that is not justification enough to charge more for a subpar product. Rather than raise premiums for customers who aren't receiving any value for what they're already paying, perhaps they can look into cutting some executive pay. Thank you for considering this matter and I hope you will not allow Healthfirst to take advantage of its customers any further.

This is concerning as with the recent repeal of the federal individual mandate we will be seeing many insurance providers utilize this change to boost their bottom lines. I think DFS needs to seriously see the profit margins that insurance companies benefit from already and do not need to take further funds from our hard working pockets. This smells unfair for the average individual. Please refuse this pocket lining initiative by Healthfirst PHSP. I currently have aSilver Plan. Thank you.

I am protesting the proposed 21% premium increase for 2019. Currently, with my limited income, High Property Tax, Mortgage, Utilities, Car and Property Insurance and other everyday expenses, this increase is unaffordable. Additionally, lack of quality and health professionals, high deductible and limited services is especially burdensome. These factors in itself do not warrant a rate increase of any kind. This plan (Healthfirst Gold Leaf) must have better managed care and more affordable rates. The proposed rate increase will force my family and many others to drop this health plan.

Healthfirst PHSP, Inc.Individual2019 Public Comments

I am a Although I work full time for 5 different non-profits, none offer health benefits, so I have greatly relied on the marketplace for my insurance for the past several years. Each year my premiums have continued to increase; my first plan was only $98 a month and now I pay $340 a month. My premium has already increased once (in January 2018) since I renewed in November 2017 and is now set to increase again in January 2019. If the rates continue to increase, I will no longer be able to afford these premiums. It's devastating to me that this system, set up specifically for people like myself,

, is failing me. I know others in my position who are purposely refusing work so that they can make a lower salary and qualify for affordable insurance. When that is the case, you know that the system must be deeply flawed. I beg you to reconsider these premium increases and think about those of us in the middle range of income who cannot afford expensive premiums but who cannot qualify for higher tax credits or medicaid. I have been very happy with Healthfirst for the last several years and wish to remain a customer but if my premiums continue to spike, I truly do not know where that will leave me. Please consider the middle class, quickly disappearing in this country, who deserve respect and a place in the system. Thank you.

To whom it may concern In 2017 there was 17% increase and year over year there has been 10% average increase now i see the proposed is about 15% increase in premiums. With enrollment going down there should be a modest increase of about 5% to 10% not the 15% i see on the proposed increase.

Healthfirst PHSP, Inc.Individual2019 Public Comments

The DFS should reject HealthFirst PHSP Inc.'s request to increase the rate for its platinum-level enrollees by 21%. For reference, one plan that would be affected is the HealthFirst Platinum Leaf (i.e., Premier) plan. The insurer is trying to keep the average of its increases across all plans to 15%, which is why its bronze plan is only being increased by 6%. DFS should reject the proposed increases for FOUR reasons. REASON #1. By overburdening its platinum-level enrollees, HealthFirst allows itself to charge a lesser premium to its bronze-level enrollees. However, the downside to a lower increased rate for the bronze-level premium is that the bronze-level deductible out-of-pocket cap have also been increased to an improperly high rate. This is not revealed in the NYS DFS paperwork having to do with premiums only. HealthFirst instead should institute greater premium parity across all its plans. The bronze level should pay more per month, and thus HealthFirst should be compelled to charge them less for deductibles out-of-pocket expenses. REASON #2. The rate increase unfairly improperly affects enrollees would-be patients that have opted for greater coverage. The very concept of insurance is that the up-front financial burdens are correctly shared. Those that have elected for greater coverage should not have to pay so egregiously more than those that have not. This is because HealthFirst has not disclosed the amount its platinum-level enrollees have cost the insurer above what they have contributed. Contrary to popular opinion, most platinum-level enrollees are not high risk and do not have pricey pre-existing conditions. They are individuals who are risk-averse and who would rather pay for all their coverage per month than risk having an expensive outlay such as an emergency room or outpatient deductible. HealthFirst has requested the 21% increase with the expectation that the NYS DFS will assume all platinum-level enrollees are costing (taking out) more than they are paying (putting in). However, we should stress that ALREADY platinum-level enrollees make up only 10.6% of HealthFirst's customers BUT contribute to 14.67% of HealthFirst's revenues. By contrast, the breakdown for the silver level is 29% / 28% and for the bronze level is 25% / 24%. Platinum-level enrollees already contribute more than 4% of what they represent. HealthFirst has not shown that they are costing the company more than this amount -- or, more particularly, much more than this amount, given the very business model of insurance companies. REASON #3. Before HealthFirst can request that monthly premiums for its platinum-level plan be increased by 21%, it must demonstrate that the 15% average increase across all plans reflects the reality of its operating budget and any increases in medical costs that it might experience. My contention is that IT DOES NOT. The 15% increase is a projected forecast based on variables that are, well, variable. HealthFirst does not yet know how differently the 2019 will be from 2018. Right now, fully 80% of HealthFirst's revenues come from government programs. EIGHTY PERCENT. These are revenues earmarked for disabled, elderly, or low-income enrollees -- the same individuals that we would deem the most medically high risk and thus the most expensive to cover. If there are increases to the medical costs of covering these people, they would be offset by the government programs that HealthFirst utilizes. HealthFirst should not burden the population of its enrollees that are able to pay for coverage (at the gold and platinum levels) because it fears that government contributions will not match medical costs. Instead, HealthFirst should make itself better at making sure it is able to receive / acquire / procure / wrest these funds. HealthFirst should not continue to assume that its platinum and gold level enrollees are either tremendously wealthy or captive to their illnesses. They are not -- they are holding up their end of the contract that is called insurance because they are slightly more fortunate than others, especially those that need government assistance. REASON #4. The NYS DFS should reject HealthFirst's request to increase the monthly premium on its platinum level by 21% and across all plans by 15% BECAUSE NEW YORKERS ARE RIGHT NOW GREATLY DISADVANTAGED BY THE RECENT FEDERAL TAX LAW. There no longer is the guarantee that the cost of health care for individuals will be offset by the tax deductions that these individuals can make relating either to their health care or to other aspects of their lives. The authorities in New York State must view these requests to increase rates by health insurers NOT as an accounting game as it benefits these companies BUT as part of the overall costs that citizens must bear living in a state where the tax structure has recently become hostile to all income levels. Please think of enrollees not as numbers but as people that must balance their checkbooks every month. HealthFirst has not demonstrated that its platinum-level enrollees are part of the millionaire class -- although there is no way to prove this, nevertheless HealthFirst is proceeding as though its platinum level enrollees can be taxed at a higher level. We are not all millionaires. We are

Healthfirst PHSP, Inc.Individual2019 Public Comments

merely trying to do the right thing, not just for ourselves, but also for the company that provides us insurance coverage and other individuals that might require greater medical attention than we do. I think HealthFirst should do the same and put individuals ahead of the extra dollars it hopes to extract from us on top of the money it already gets from the government. Thank you for reading. ADDITIONAL NOTE: The left panel on this page states that the contact information (address telephone number) is optional for people commenting on this page. Despite this your website has mandatory asterisks (*) for all these fields. I am proceeding as if these fields are optional, but I am providing my email and phone number. I look forward to your reply and I look forward to learning the news that HealthFirst's rate increases are less than what they are proposing.

You've got to be kidding. My husband and I are hardworking stiffs who don't bring home much money after taxes. It's all we can do to stay in New York City for work reasons, paying $5,000 a month rent plus bills, raising teenagers. We can hardly make ends meet as it is! We're already paying $2,026 a month for health insurance - that's like paying a second rent - and you're RAISING OUR PREMIUMS AGAIN? We will not be able to afford health care coverage if you do this. And trust me, it will end up costing taxpayers more in the end because people like us will have to go to the E.R. anytime one of us is sick, instead of a simple visit to our doctor. YOU CANNOT DO THIS.

Dear Madam or Sir, RE: Healthfirst PHSP, Inc. and their requested premium increase of 21% INSURER: Healthfirst PHSP, Inc. PLAN: Healthfirst Platinum Leaf Premier COVERAGE: Individual HIOS ID NUMBER: 91237NY0020058 NO INCREASE IS NEEDED I write to protest and object to their request for a 21% premium increase. —Healthfirst received a 26% rate increase for 2018. —In 2017, Healthfirst was paid $7893.24 by me and the State of New York. —Healthfirst paid out only $3971.26 —They made a profit of $3921.98 —That’s a 99% profit Do they now want to triple their profit? Insurance profits are at an all-time high. But I’m barely making enough to pay my bills each month, and they’re saying 100% profit off me and the state isn’t enough? That’s ridiculous. Especially considering how they treat their clients. —Crappy service: Telephone service people are badly trained, don’t know what they’re talking about and can’t help or advise. —They always ask for 2 months advance payment! I’ve never heard of anyone asking for 2 months payment in advance! Do they think we own yachts and spend summers in the Hamptons? —They always send letter by mail claiming I haven’t paid when I have. So I have to call up and they tell me ‘O sorry, the system is behind’—and this is the middle of the month. They claim there have been increases in costs. But they made nearly 100% profit off me and the state of New York. Have medical costs gone up 100%? I don’t think so. They don’t deserve an increase in my premium because —the cost of medical services doesn't warrant it, —their treatment of clients is disrespectful, —the hardship it will cause me scraping together the money to pay, and —things I need but won’t be able to buy if they get more. I ask you please, please, please, do not give them a premium rate increase. Kind Regards,

Healthfirst PHSP, Inc.Individual2019 Public Comments

NO INCREASE IS NEEDED I write to protest and object to their request for a 21% premium increase. —Healthfirst received a 26% rate increase for 2018. —In 2017, Healthfirst was paid $7893.24 by me and the State of New York. —Healthfirst paid out only $3971.26 —They made a profit of $3921.98 —That’s a 99% profit Do they now want to triple their profit? Insurance profits are at an all-time high. But I’m barely making enough to pay my bills each month, and they’re saying 100% profit off me and the state isn’t enough? That’s ridiculous. Especially considering how they treat their clients. —Crappy service: Telephone service people are badly trained, don’t know what they’re talking about and can’t help or advise. —They always ask for 2 months advance payment! I’ve never heard of anyone asking for 2 months payment in advance! Do they think we own yachts and spend summers in the Hamptons? —They always send letter by mail claiming I haven’t paid when I have. So I have to call up and they tell me ‘O sorry, the system is behind’—and this is the middle of the month. They claim there have been increases in costs. But they made nearly 100% profit off me and the state of New York. Have medical costs gone up 100%? I don’t think so. They don’t deserve an increase in my premium because of —the 100% profit they're making already, —medical services provided don't cost enough to warrant an increase, —their shoddy treatment of clients, —the hardship it will cause me scraping together the money to pay, and —things I need but won’t be able to buy if they get more. I ask you please, please, please, do not give them a premium rate increase. Kind Regards,

This proposed increase is absurdly expensive will simply cause more people to drop out causing more revenue problems. This is not a fair solution for those of us who are funding the current system.

I should not be required to make increased payment of premium for insurance since i am a minimum wage earner and have no other source of income. Additionally, I have incurred no charges towards my policy and feel that there is no understandable reason for my having to pay increased charges.

Healthfirst PHSP, Inc.Individual2019 Public Comments

I got my first Healthfirst insurance policy in 2016, at the suggestion of one of my doctors, even though the premium was an increase from my other insurance provider. The premium was $496.31, with a $600 deductible. During the 2016 year, I did not visit doctors enough to meet my deductible. I received a letter in May 2016 stating that Healthfirst was requesting a rate change of 6.5%. DFS approved a rate change of approximately 7%, bringing my monthly premium to $532.91 for the 2017 year, still with a $600 deductible. I did not come close to meeting my deductible, again. In May 2017, I received a letter stating that Healthfirst intended to raise my premium by 20%. That is an unbelievable additional hike of 14%. DFS approved an increase of approximately 15%, bringing my monthly premium to a whopping $611.61, still with a $600 deductible. In the six months of this year so far, I have seen one doctor. I do not expect to meet my deductible for a third year in a row. Last year I paid $6,394.92 plus whatever I owed to my deductible for my few doctors visits. Since I am being forced to buy insurance, I consider that $6,394.92 stolen money. Last month I received the letter from Healthfirst stating their proposed rate hike of an incredible 21%! If DFS approves that amount, I will be paying $740.05. A month! On top of the $600 deductible. I cannot afford to pay $8,880.60 for health insurance that does not get used. This is an outrageous amount. In the three years, the increases amount to $2924.88. In ONLY three years. In this 21% rate increase is approved, I will be forced to find a lower-priced policy (if one exists) with a different carrier, or give up health insurance all together.

I find this company's request for a 21% rate increase unreasonable if not outrageous. This plan costs $640 per month already, and this company still refuses to pay for even modestly-priced therapeutic devices like that are routinely prescribed by . Moreover, this company's web site deliberately misrepresents which medical providers actually accept its insurance. I purchased insurance from this company in reliance on the information contained on its web site, only to discover afterward that many of the providers it lists on its website as in-network providers do NOT actually accept HealthFirst. For this reason, I am not sure that this company should be allowed to sell insurance in this state at all, much less be permitted to raise its already exorbitant rates.

A 21% increase this year, after a significant increase last year feels like robbery to me! Who is in charge of the hen house? Is it the fox???

Healthfirst PHSP, Inc.Individual2019 Public Comments

I currently have a Healthfirst Bronze Premium Leaf Plan through ACA. For the first 4 months of 2017 I had a Silver Leaf Plan, which I canceled because the premiums and deductible, even with my tax credit, were too high. I did end up requiring medical attention and was subject to the penalty for non-coverage for that tax year. It was more affordable than what I would have paid had I continued my coverage. I'm up against the same decision this year; I've been covered for 6 months and am considering canceling. I am currently dealing with a health issue that I cannot afford to treat because of my $4,000 deductible. I will pay hundreds of dollars just for the diagnosis I received, which was only a general diagnosis because I could not afford the two my doctor advised me to get. However I cannot afford to be treated. If I could get back the $1,500 I've spent on premiums so far this year, I would be able to pay for my treatment out of pocket free from the hassle of dealing with my insurance company. My current Premium health plan is nothing more than an extraordinarily expensive catastrophic plan. Pardon my french, but this is and everyone knows it. You'll let them raise their premiums anyway. I won't be able to afford it and I will not have health coverage in 2019.

ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails.

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Re:Plan: Healthfirst PHSP, Inc.Healthfirst Gold Leaf PremierIndividual CoverageHIOS # 91237NY0020056

To Whom it may concern,

A proposed 27%rate increase to my premium is absolutely unjust and frankly insane!! I already pay $640 a month with a deductible of $900 and with a 21% increase it would make my monthly payment $774.40 + deductible which would be un-affordable. The whole of 2018 - I've only visited the doctor once in 6 months so far!! The whole point of the marketplace is AFFORDABLE health coverage! What do you propose I do for health insurance in this scenario? I'm already stretched monetary to afford the healthcare coverage I have now!! Please don't approve this change. I see no reason for it as these health insurances make enough money as it is!!

Sincerely,

Actors Fund African Services Committee Children’s Defense Fund-New York

Community Service Society of New York Consumers Union Empire Justice Center Make the Road New York Medicare Rights Center Metro New York Health Care for All Campaign New Yorkers for Accessible Health Coverage New York Immigration Coalition Project CHARGE

Public Policy and Education Fund of New York/Citizen Action of New York Raising Women’s Voices-New York Schuyler Center for Analysis and Advocacy Small Business Majority

Young Invincibles

Health Care For All New York c/o Amanda Dunker, Community Service Society of New York

633 Third Ave., 10th Floor, New York, New York 10017 (212) 614-5312

June 28, 2018 Maria T. Vullo, Superintendent Troy Oechsner, Deputy Superintendent for Health John Powell, Assistant Deputy Superintendent for Health NYS Department of Financial Services One Commerce Plaza Albany, NY 12257 RE: Requested Rate Changes – Healthfirst PHSP– Individual – 131487115 Dear Superintendent Vullo, Deputy Superintendent Oechsner, and Assistant Deputy Superintendent Powell:

Health Care for All New York (HCFANY) is a statewide coalition of over 170 organizations dedicated to achieving quality, affordable health coverage for all New Yorkers. HCFANY believes that the public rate review process is a vital consumer protection and is grateful for the opportunity to submit comments on the rate requests submitted for 2019’s individual plans. The comments below address concerns about the market as a whole before offering specific comments on Healthfirst.

I. Market-Wide Comments

A. Action is needed beyond the rate review process to stabilize New York’s individual market.

HCFANY is concerned that New York’s insurance companies have not successfully

controlled costs in the individual market. This year, the carriers seek an average 24 percent rate increase for the 2019 individual market plans.1 This is the fifth year in a row that the requests have been in the double-digits for the individual market (the previous four years of requests and approved rate changes can be seen in the chart below).

1 New York State Department of Financial Services, “Proposed 2019 Health Insurance Premium Rates for Individual and Small Group Markets,” June 1, 2018, https://www.dfs.ny.gov/about/press/pr1806011.htm.

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Average Requested and Approved Premium Increases New York’s Individual Market 2015-20182

Request (Percent) Approved (Percent) Percent Change 2018 17.7 14.5 -18.1 2017 19.3 16.6 -13.9 2016 10.4 7.09 -31.8 2015 12.5 5.7 -54.4

Such large increases cause immense hardships for those New Yorkers who receive little

or no financial assistance through the NY State of Health Marketplace. Fortunately, most people (59 percent) in the Marketplace do receive help through tax credits that are based on income and grow as prices increase.3 As a result, many are insulated from rate increases. However, 41 percent of people who enrolled in qualified health plans last year received no assistance.4 That means they bear the full brunt of any approved premium increases. HCFANY is concerned that approving rate increases so far above the rate of medical inflation will eventually result in enrollment declines and ultimately, an insurance “death spiral” that would catapult premiums beyond the reach of anyone ineligible for assistance.

HCFANY commends the Department for its past efforts to safeguard consumers by reducing the carriers’ average rate increases substantially and urges it to do so again this year. HCFANY’s recommendations for doing so, based on a close reading of the applications, are below. HCFANY additionally asks that the Department and other state leaders take more forceful action outside of the rate review process to stabilize the individual market. High premiums force New Yorkers to choose between health care and necessities like housing and food.5 Those choices continue even after someone gains coverage as they make their monthly payments and face increasing cost-sharing.6 High premiums also contribute to disparities in well-being between white Americans and others. Adults who are black are much more likely to report an inability to afford basic necessities and health care than adults who are white.7 Adults who are black or Hispanic are more likely to have had medical bills turned over to debt collectors than those who are white.8

2 For 2018, see https://www.dfs.ny.gov/about/press/pr1708151.htm. For 2017, see https://www.dfs.ny.gov/about/press/pr1608051.htm. For 2016, see https://www.dfs.ny.gov/about/press/pr1507311.htm. For 2015, see https://www.dfs.ny.gov/about/press/pr1409041.htm. 3 New York State of Health, 2018 Open Enrollment Report, May 2018, page 5, https://info.nystateofhealth.ny.gov/sites/default/files/NYSOH%202018%20Open%20Enrollment%20Report_0.pdf. 4 Ibid. 5 NORC and the West Health Institute, “Americans’ Views of Healthcare Costs, Coverage, and Policy,” March 2018, page 2, http://s8637.pcdn.co/wp-content/uploads/2018/03/WHI-Healthcare-Costs-Coverage-and-Policy-Issue-Brief.pdf. 6 NORC and the West Health Institute, page 8. 7 Ibid. 8 NORC and the West Health Institute, page 6.

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The role of private insurance companies is to pool risk for large numbers of enrollees and negotiate and control prices on their behalves. This year, as in the past, the carriers’ applications state that providers are so powerful that this process cannot take place. If this is true, New York should take steps to control prices in the individual market and ensure that people who purchase their own plans have affordable coverage options. Other states have been more successful in keeping prices down in the individual market. For example, Minnesota has implemented a reinsurance program that has resulted in substantial declines in its individual market rates (between 3 and 12 percent).9 To control prices in the individual market, New York should consider the following strategies:

1. Provide premium assistance to people who make above 200 percent of the federal

poverty level. Increased premium assistance would stabilize prices by increasing the size of the risk pool. The more enrollees insurers have, the more they can spread the costs of care across individuals. Ideally, premium assistance would be available to everyone based on income. Encouraging greater participation by some groups could particularly help stabilize the individual market without great cost. Young people, for example, have lower incomes and lower health risks than older people. This means they are more likely to gamble against buying health insurance when dealing with tight budgets. Providing assistance to them would attract more people into our individual market who are lower risk. Insurers would be able to lower costs benefitting many in the market, and young people would have financial security in the event of a health emergency.

2. Create a drug utilization review board for commercial plans in the individual market

similar to the review board that exists for Medicaid. All of the carriers cite increasing pharmacy prices as a reason for premium increases. For example, HealthNow estimated that medical prices would only increase by 3 percent while pharmacy prices would increase by 9.5 percent. Since so many insurance companies report being outmatched by the pharmaceutical industry, the state should consider intervening. New York’s Medicaid program has a Drug Utilization Review Board charged with reviewing clinical information and making recommendations to the Commissioner of Health on drug coverage.10 The Board’s meetings are public, it includes consumers, and the process for nominating members is transparent. Such a Board could ensure that consumers benefit from any rebates and could negotiate for lower pharmacy costs across the market.

3. Consider a public option such as an Essential Plan Buy-In Program. The state should

allow more people to participate in the Essential Plan as an affordable alternative to the individual market. The Essential Plan provides comprehensive coverage to people who earn between 138 and 200 percent of the federal poverty level.11 Participants at the highest

9 Minnesota Commerce Department, “Health insurers propose decreased average rates for Minnesota’s 2019 individual market,” June 15, 2018, https://mn.gov/commerce/media/news/?id=342571 . 10 New York Department of Health, Office of Health Insurance Programs, “Medicaid Drug Utilization Review Board General Operating Procedures,” https://www.health.ny.gov/health_care/medicaid/program/dur/docs/operating_procedures.pdf. 11 Empire Center, “A surprising surplus in Albany,” February 14, 2018, https://www.empirecenter.org/publications/a-surprising-surplus-in-albany/.

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income level pay only $20 a month; the cost of their care to the state is minimal because most funding comes from the federal government.12 New York could allow people with higher incomes to participate in the Essential Plan and offer state subsidies on a sliding scale. At a minimum the state could allow people to pay full-price to participate in the Essential Plan.

Other states have adopted additional measures that may be worth considering, such as the

state-based individual coverage mandates recently adopted by New Jersey and Vermont.13 Massachusetts has also had an individual mandate in place since 2006.14 Alternately, New York could seek a 1332 Waiver to establish a reinsurance program along the lines of Minnesota or Alaska.15 Finally, New York should seriously consider stepping in for the plans and controlling costs more directly through a Maryland-style global payment model.16 All of these ideas—and more—bear scrutiny in the face of the carriers’ substantial and persistent rate requests and HCFANY urges the Department to establish an Advisory Commission to explore them.

B. Within the rate review process, there are several areas in which we respectfully ask

DFS to question insurers’ arguments and impose greater standardization in their requests.

It is evident that federal activity has had a modest impact on New York’s individual

market. However, New York State has taken important steps to protect companies from those actions. Those steps included increasing the budget for enrollment assistors in the 2019 budget and opting to maintain the three-month open enrollment period. Additionally, under New York’s strict laws, the carriers face little threat from the federal liberalization of rules governing association health plans.

As a result of the state’s actions and an improved economy, New York’s individual

market appears to be stable—not contracting as some carriers claim. The New York State of Heath boasted an overall increase of 4 percent in 2018 enrollment.17 Although New York’s individual off-exchange marketplace lost enrollment, that appears mostly to be a self-inflicted wound imposed by the actions of one carrier (Empire) which terminated its entire line of

12 Ibid. 13 Katie Jennings, “New Jersey will become second state to enact individual health insurance mandate,” Politico New Jersey, May 30, 2018, https://www.politico.com/states/new-jersey/story/2018/05/30/new-jersey-becomes-second-state-to-adopt-individual-health-insurance-mandate-442183. 14 Ibid. 15 Cheryl Fish-Parcham, “Alaska’s Reinsurance 1332 Waiver: An Approach that Can Work, Families USA, August 2017, http://familiesusa.org/product/alaska-reinsurance-1332-waiver-approach-can-work and 2017 Minnesota Session Laws, Chapter 13—H.F.No.5, https://www.revisor.mn.gov/laws/?year=2017&type=0&doctype=Chapter&id=13. 16 Shah et al., “Maryland’s Global Budget Program: Still an Option for Containing Costs,” The Commonwealth Fund, April 3, 2018, https://www.commonwealthfund.org/blog/2018/marylands-global-budget-program-still-option-containing-costs. 17 Burton et al., “What Explains 2018’s Marketplace Enrollment Rates?,” Robert Wood Johnson Foundation, June 2018, https://www.urban.org/research/publication/what-explains-2018s-marketplace-enrollment-rates.

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individual market products, causing disruption and panic amongst its 50,000 members.18 In addition, more New Yorkers may be securing job-based coverage as the economy has improved. Despite these two trends, with a few minor exceptions, nearly all the other plans gained members between 2017 and 2018.

These conditions may not be adequately reflected in the 2019 rate requests. Thus,

HCFANY urges the Department to carefully review the carriers’ filings in a manner that ensures consistency of rate actions in the following areas: (1) the individual mandate; (2) trend; and (3) administration costs.

1. Increases due to the loss of the mandate should be reasonable and companies with

similar risk profiles should receive similar increases. In 2019, the federal tax penalty for failure to purchase health insurance will be

eliminated. The carriers’ applications contained varied estimates of the impact of this change with adjustments ranging from 0 to 23 percent. It is plausible that the variation of estimates is due to a carrier’s claims experience and premium levels (which make the plan more or less likely to be attractive to someone on the fence about buying a plan). However, this explanation for the diversity of estimates is belied by the fact that carriers with apparently similar risk profiles are asking for vastly different increases. For example, Oscar and Fidelis have similar average claims costs, yet Fidelis asks for a 23 percent increase to make up for losing the mandate while Oscar asks for just 7 percent.

To ensure that all New Yorkers in the individual market are treated fairly and equitably,

the Department should consider imposing a cap on the individual adjustment mandate—such as 6 percent, which is the average across all carriers. Those carriers that filed adjustments below 6 percent should be granted the adjustments that they seek (e.g. 0 to 6 percent) and everything above would be reduced to 6 percent.

2. Medical trend estimates vary too much. The state should require a standardized

trend, either for the entire state or for regions. The carriers estimate medical trend between 5.1 and 11.5 percent. While most of the

trend requests are within the ranges seen in national estimates (between 4.5 and 8 percent), there are reasons to think that New York’s insurers could do a better job of managing these costs.19 For example, many of New York’s plans only offer in-network coverage and those networks are

18 Empire’s 2017 Rate Filing indicates that it had 54,000 members, while its 2019 filings now indicate that it has just 24,000 enrollees. In the interim, Empire retired its individual market offerings and re-filed a new product that was 47 percent more expensive than its predecessor. 19 American Academy of Actuaries, “Drivers of 2019 Health Insurance Premium Changes,” June 2018, http://www.actuary.org/files/publications/Premium_Drivers_2019_061318.pdf; Girod et al., “2018 Milliman Medical Index, May 2018, http://www.milliman.com/uploadedFiles/insight/Periodicals/mmi/2018-milliman-medical-index.pdf; and PwC Health Research Institute, “Medical Cost Trend: Behind the numbers 2019,” June 2018, https://www.pwc.com/us/en/health-industries/health-research-institute/assets/pdf/hri-behind-the-numbers-2019.pdf

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increasingly small.20 Most estimates of annual medical trend changes are based on information from the employer market, where networks and benefits are often more expansive. That could be a reason to believe that medical trend should be lower for New York’s narrow network plans.

Additionally, it is unclear why carriers in the same state and even in the same regions of

the state should report such variation in medical trend. Each year, HCFANY notes in our rate review comments that the carriers do not provide enough information about how they arrive at their trend estimates. While the applications have improved in some ways over the years (for example, fewer redactions), not enough applications include a breakdown of trend into pharmacy versus medical costs. When they do, the carriers rarely provide a narrative explanation of how they manage costs, other than to argue that provider consolidation means they cannot reduce medical spend.

As an intermediate step, the Department should consider requiring carriers to provide

better information about their trend estimates. The most helpful way for carriers to provide this information is through a trend breakdown showing the following: inpatient facility care, outpatient facility care, professional services, pharmacy, and other. This is helpful because it is the way that the Milliman Medical Index is reported, which provides a comparison point.21 Some carriers did provide that information, including Excellus, Healthfirst, and Independent Health. Additionally, if all carriers provided this information the public would be able to compare their own insurer’s performance to a statewide or regional average. HCFANY recommends that either Exhibit 18 or 13a be modified to require this information, or that the Department creates a new exhibit that shows a detailed trend breakdown.

More importantly, the Department should consider adopting a standardized medical and

pharmacy trend cap for individual market carriers and requiring them to stay under the state limit. This measure could be implemented on a statewide or regional basis.

3. Administrative costs should be decreasing over time. The Department should

consider imposing a cap to guard against extraordinary administrative costs. Overall plans are asking for slightly lower administrative costs this year (12.1 percent

versus 13.9 percent in their requests for 2018). But plans have had six years of experience operating in this market. New York State invests significant resources into marketing qualified health plans and making it easy for people to enroll and renew. The Department should investigate why administrative costs have not decreased more, and closely question plans whose administrative costs are increasing.

The range of administrative costs in the 2019 requests is also very wide, from 8.2 percent

to 17 percent. Companies that spend much more of their premium dollars on administrative costs than peers should explain their performance in a detailed manner. Above-average rate increases from companies that also have above-average administrative costs deserve special scrutiny. The 20 University of Pennsylvania/Robert Wood Johnson Foundation, “State Variation in Narrow Networks on the ACA Marketplaces,” August 2015, http://ldi.upenn.edu/sites/default/files/rte/state-narrow-networks.pdf 21 Girod et al.

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Department should also consider imposing a cap on administrative costs that are far above average.

II. Issues Specific to Healthfirst

With 29,055 members, Healthfirst is New York’s third largest insurer. It operates in the New York City and Long Island regions. A notable feature is that Healthfirst has fairly low claims costs compared to other plans. Its average claims cost per-member per-month is only $335, much lower than the average (which was $511) and the third lowest in the market.22

Healthfirst is requesting an average increase of 15 percent for its 2019 rates. This is

slightly below the average for New York’s individual market (which was 17.8 percent) but is still high enough to cause hardship to its members. Healthfirst was one of only three carriers that lost individual market members between 2017 and 2018 (a 6 percent decrease). This is likely the result of last year’s 17.7 percent increase in rates. Another large increase may drive even more customers away.

HCFANY has identified four issues to review for Healthfirst: its high expense ratio, its

medical claims trend, its treatment of dental and vision coverage, and its redaction of information about its provider network.

A. Healthfirst’s administrative costs are higher than average and increasing when

they should be decreasing.

Across the individual market, carriers seek a 12.1 percent administrative cost request. Healthfirst requested 15 percent, one of the highest filed this year. Healthfirst is a nonprofit plan which should experience lower administrative costs. The only plans with higher administrative costs than Healthfirst are the for-profits Oscar and United.

In 2017, Healthfirst’s administrative costs were only 12.8 percent. The company’s

administrative costs increased again last year to 14.6 percent. As discussed in the general comments, it is unclear why any carrier should experience increasing administrative costs after years of experience in this market.

There is no explanation in Healthfirst’s Narrative Summary or Actuarial Memo for its

increasing administrative costs. The Department should consider reducing this part of Healthfirst’s request to its 2017 levels or below.

22 These are CDPHP, Empire Health Choice, Excellus, Healthfirst PHSP, HIP/Emblem Health, NYQHC/Fidelis, HealthNow, IHBC, MetroPlus, MVP Health Plan, Oscar, and Unitedhealthcare of New York. An additional four plans were offering plans off-exchange only, all with under 150 members. Those four plans were not included in the analysis for HCFANY’s individual rate comments.

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B. Healthfirst estimates a medical trend that is slightly lower than average, but as a

provider-sponsored plan it might be expected to perform better than average. Healthfirst estimates a medical trend of 6.5 percent, which is less than the average

requested trend for New York carriers (7.3 percent). However, in 2017, Healthfirst’s trend was just 4.5 percent. Healthfirst’s Actuarial Memo does not provide insight into why its trend is increasing when national experts suggest that trend is stabilizing or even decreasing over the same period of time.

As a provider-sponsored plan, Healthfirst is in an especially good position to negotiate

contracts that should benefit its membership. Healthfirst was one of only four carriers to provide a full breakdown of its medical trend into inpatient facility services, outpatient facility services, professional services, and pharmacy. This is important information for the public for understanding insurance rates and for helping New York develop solutions for high premiums. Since there are only four full examples, comparisons may not be especially meaningful. However, it is interesting that Excellus reports lower trend rates than Healthfirst for inpatient services (2.9 percent versus Healthfirst’s 3.6 percent) and professional services (1.4 percent versus Healthfirst’s 3.6 percent). Healthfirst did perform the best of the four on outpatient facility services.

There is better information about how pharmacy trend compares across plans (eight of

the twelve provided this information). Healthfirst’s estimate for pharmacy trend was slightly above the average (11.5 percent versus 13.2 percent).

As noted above, HCFANY asks that the Department examine all the carriers’ claim

trends closely to look for areas in which the companies can better control costs. And while Healthfirst’s trend is below the average sought by the other carriers, it should still be reduced given its own historical experience and that it is a provider-sponsored plan.

C. Healthfirst appears to distribute the cost of dental and vision coverage to all plans, regardless of whether those services are covered.

Healthfirst cites dental and vision costs as a 2.1 percent factor in its rate increase that

would affect all Healthfirst plans, both standard and non-standard. However, standard plans do not offer dental and vision coverage and should therefore not be burdened with this portion of the rate increase. Additionally, non-standard plans that offer dental and vision coverage have higher monthly premiums, so the costs related to dental and vision coverage should already be accounted for in those higher premium rates.

The Department should require Healthfirst to justify why it seeks to assess a cost on these

benefits that have already been factored into the premiums for non-standard plans and which should have no effect on the premiums for standard plans.

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D. Healthfirst redacted information about provider rates.

Healthfirst redacted the amount of its provider reimbursement increases. Healthfirst’s

nonprofit status and its close relationship to the hospital industry should give it particularly strong bargaining power to keep rates low. Its status as a provider-sponsored plan also makes the rates it pays providers a matter of particular public interest. In any instance, redacting this pertinent information deprives consumers of their right to know what they are paying for when they choose a health insurance plan.

HCFANY urges DFS to carefully review the application submitted by Healthfirst. Thank you for your attention to these comments. Please contact us with any questions at adunker@cssny.org or 212-614-5312.

Sincerely,

Amanda Dunker, MPH Mark Scherzer, Esq Health Policy Associate Legislative Counsel Community Service Society of NY New Yorkers for Accessible Health Coverage