Health Insurance Plan of Greater New York Individual 2021 ... · Thank you. recieved letter from...

Health Insurance Plan of Greater New YorkIndividual2021 Public Comments

THIS RELATES TO EMBLEMHEALTH. I can't find EmblemHealth on your list above, but they are applying for a whopping 9.5% increase to my health insurance. At this time, in light of job losses and a pandemic, is this really appropriate? No. It is not. This plan is already cost over $700 a month. Please do not let them have this increase as individuals struggle to recover from the pandemic.

I am writing you to request that premium increases be denied for this year due to the economic devastation caused by the covid-19 pandemic. It is challenging enough for people to try and remain healthy amid a pandemic with historic levels of unemployment. Adding premium increases on top of this will make it impossible. Thank you.

Please DO NOT APPROVE a rate increase for 2021, especially not 9.5% and especially not in a time of economic recession -- not just in our country, but specifically here in NYS. COVID-19 has caused many people to be out of work (myself included, whose workload has been decreased to less than half time) and reliant on unemployment benefits and/or pandemic assistance, which barley provides for cost of living. The rates for insurance are already outrageous despite being deemed affordable, and the income of working minimal hours with pandemic assistance makes it next to impossible to continue to afford. It seems I make just enough money to be over the threshold for being provided with financial assistance, so I am responsible for 100% of the already expensive rate. A rate increase of 9.5% would very likely lead to my not being able to continue to afford insurance, leading to a greater burden on me and increasing the likelihood I will actually need medical assistance due to the well-researched effects of prolonged stress on one's overall health. To date, I have maintained good health and have not needed to use my insurance at all this year. In short, when considering the recent economic recession, expected continuation and/or resurgence of COVID-19 and its devastating financial impacts, and the already challenging rate of insurance premiums, I strongly and pleadingly request that you refrain from approving a rate increase for the upcoming 2021 plan year.

My wife and I are struggling to pay our current premiums of $1,509.00/month...and that represented an increase of 10% from the previous year!!! We lost our side business as a result of COVID-19. I've not had a salary increase since 2009...and Emblem Health is requesting another 9.5% increase??? Are they kidding??? Where the hell does this end???That's almost a factor of 4 greater than inflation. Clearly, the goal here is to make it so no one can afford health insurance which means it will fall on the state or the federal government. At this point, with this increase, we will no longer be able to afford health insurance (first time in years) and like millions of others, our health and its management will become a problem for the state. These increases are criminal and should not be permitted. I'm guessing that Emblem Health management has been enjoying yearly salary increases as those of us struggling to be responsible citizens wither on the vine and end up in the trash bin of society.


For the past few years Emblem Health has regularly increased monthly payments by almost 10%. As it stands, I pay $663 a month for health insurance. To see a specialist, I pay a $70 co-pay. These fees are incredibly cost prohibitive and have caused me to stop seeing specialists unless i'm critically ill. To call this 'affordable' healthcare for a person who is relatively healthy is a joke. During this covid crisis, I have thought about seeking a therapist to address ,but spending the additional $140 a month for that specialist is fiscally irresponsible in a shaky economy. If the goal is formore Americans to have insurance, and participate in the marketplace, these types of fees and increases are directly counter to that.

Emblem Health Gold Member I do not understand how my healthcare could POSSIBLY increase to where it is now, and get a letter today, stating it will rise yet again in 2021! I am a SINGLE man with ZERO children and I am somehow currently paying almost $1000. monthly! How can this possibly be? As Emblem Health can clearly see, the last time Ive been to a doctor was a year ago! I live paycheck to paycheck and and I'm struggling. A single man, without children, pays 1k a month, and is threatened with another hike?? Outrageous, and I would very much like the opportunity to switch OUT of emblem health altogether. I have been unemployed since FEBRUARY 2020 without being able to find work due to CORVID, and UNABLE to get unemployment because I was at my job for less than 6 months. This is completely unacceptable and unwarranted. Ive lived in New York my entire LIFE, I simply cannot afford this.

I cannot afford another increase. These insurers raise their premiums by 8-15% annually, and most of us are struggling to pay our bills, and haven't had a salary increase in years. Also, my insurer is Emblem Health, but it's not in your list.

I do not support this 9.5% increase to health insurance premiums. As a single person who works on a contract basis (freelance), my premiums were already high at $663 per month. The insurance benefits aren't even that good—they put me and other members through so many hoops just to see a doctor or specialist. You have to go see a PCP before seeing any other doctor, raking up on copays. If you need physical therapy and have a plan that includes 60 visits, like me, you have to prove you need PT after only a couple visits. It's rare that you even get 6 visits before having to appeal for more. Since COVID, I been unemployed but still paying my health insurance. My finances have taken a hit and it'll take a while to get back on track. This increase to premiums may result in me having to decide whether or not I can keep it.

9.5% increase is absurd. Cost of living increase is fine. Sorry no MORE!!!


My insurer is EmblemHealth, but it wasn’t an option in your dropdown. I’ve been a freelancer for 10 plus years, and every year, my insurance premium goes up by about 8-12%, but my income does not. This is breaking me. We should be talking about how to lower health insurance costs by cutting c-level salaries and bloated overhead costs, rather than increase them. Unregulated, health insurance has become the equivalent of the wild wild west, charging egregious premiums with very little accountability.

Please do not approve rate increases for health insurance premiums. I am already spending $900/month for coverage with Emblem Health. I'm a freelancer in the theater industry. I'm out of work and will likely be for a year while performing arts venues remain closed. The insurance system is never set up to serve freelancers. My premium is so high because it's based on previous year's income, which is never consistent or indicative of what a future year will be. Hence, I'm stuck with huge premium payments while my income has dropped dramatically. Please, if anything, find a way to reduce premiums and make a system that is more equitable to freelancers purchasing their own insurance.

Well I think, 9 % is a very high rate to raise the cost of insurance. I understand that costs go up, but my wages are not rising 9% every year. Maybe wages rise 1% every two years. I pay 663.00 per month and not everything is included. I am paying 75.00 extra for this and that. People that get this insurance are freelancers that work for small businesses. So generally, they are middle to lower income. Maybe NY State could get some advice from Kaiser Permante. That insurance is OK and at a reasonable price.

I received notification from my insurance group, Emblem Health (not listed in your dropdown) They will be requesting a premium rate increase for 2021 of 9.20%. Please, do not allow this. Shame on them for even suggesting an increase to our premiums during a health pandemic and a global financial crisis, all the while lining their own pockets. THIS IS SHAMEFUL!

I run my own consulting business. One great way for NY or any state to run small businesses like mine OUT of business is to let the insurance companies hike rates up every single year, and passing an increasingly untenable burden onto people like me. The choices are already incredibly limited, for individual insurance; the deductibles are already so substantial; and the premiums are already SO high--how are we meant to keep this up? EVERY single year my insurance rates take a leap even though my health status is still the same. IF in fact it's true that the poor, poor insurance companies are struggling to pay the increasing costs of healthcare, can we just talk about WHY ARE THE AMOUNTS CHARGED BY HOSPITALS AND DOCTORS AND LABS SO RIDICULOUSLY HIGH in the first place? And then the insurance companies don't pay anywhere NEAR those amounts yet continue to claim they have to charge micro businesses and individuals MORE and MORE? Disgusting. How much money does our repugnant profit-driven healthcare industry actually need to make, while offering, btw, nearly nothing in return? Because the insurance companies routinely refuse to pay for care when we actually get sick. Well, they need to stop charging us for nothing.


PLEASE HAVE SOME MERCY AND COMPASSION!!!!!! SO MANY OF US HAVE LOST OUR JOBS DURING THIS HORRIBLE PANDEMIC!!!! OUR RATES HAVE GONE UP EVERY SINGLE YEAR AND IT JUST IS NOT FAIR!!!!!!! PLEASE GIVE US A BREAK THIS YEAR, AT ;EAST!!! WE ARE ALL STRUGGLING TO PAY OUR BILLS AND CANNOT AFFORD AN INCREASE!!!!! WE SHOULD BE GETTING A DECREASE!!!! PLEASE, JUST OUT OF COMMON DECENCY AND COMPASSION, DO NOT ALLOW THEM TO RAISE OUR RATES THIS YEAR!!!!!!! WE NEED A BREAK!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

Dear Sirs: Please re-consider raising the insurance premium rates, especially during this uncertain time of the Covid pandemic when so many people are out of work. Speaking for myself and my wife, we are in our , I am retired and my wife works part time. Neither of us have access to medical insurance except for the Emblem Health plan we are currently on, and we are on a fixed income as well. Expenses are tight. Your rate increase will raise us up to nearly $600 more per year. With the deductible being nearly $5,000 per person, this puts us over what is affordable for us. Please reconsider and know that we are truly grateful that we have access to these plans through NYS of Health. Thank you.

recieved letter from emblem about raising premiums again. are you kifdding me. i just signed up with them on for 1 person no kids and price was like 1000 a month and then on jan 2020 rates went up over $1300 a month

for 1 person and now during a pandemic, a depression, the highest unemployment in history and you have to send a letter you want to raise preimums 9+%. is this a damn joke.

Dear DFS, I am writing to protest the exorbitant rate increase being requested by EmblemHealth (HIOS Plan ID: 88582NY0150001). A rate increase of 9.4% would bring the individual plan to $1,180.96/month ($14,171.52/year) and my estimated cost, after tax credit would rise from $840.40/month to $919.40/month ($11,032.77/year). My AGI last year was $39,323. I work in education and the performing arts, industries which are particularly hard-hit by Covid-19. I have lost a great deal of income during this crisis, and even if work can resume next year, I think it's safe to say it won'tresume at pre-Covid levels. How can I possibly afford health insurance if it is to cost nearly 30% of my income? Yet considering I have a chronic pre-existing condition, how can I survive without it? Pandemic aside, this plan cost $549.38/month ($6,592.56/year) when I first subscribed in 2016. That is a rate increase of 215%. The CPI indicates an 8.9% increase in cost of living over the same period, and while I understand health care costs rise at different rates, this proposal is outrageous and untenable. I respectfully request your office freeze insurance rates at their 2020 levels until the pandemic ends and the economy recovers. Respectfully,

Please do not allow another Emblem health rate increase. My premium is $740 per month with a hospital deductible of $5,000. I cannot go to the hospital for an Emergency because of my deductible. It's cost prohibitive and people like myself will avoid getting necessary care because of the expense. Thank you!!


It is difficult for anyone outside of Congress, drug companies, or any other government job to obtain health insurance at a reasonable cost. Health care is a necessity and it is required by law. How can something so fundamentally basic be usurped by profit and greed? How can you justify an increase of 9.5% Is this your response to the pandemic?

Due to Covid-19 patients who do not have the disease are making less trips to doctor offices and hospitals, out of fear of contracting the disease, and doctors are performing less elective surgeries. In fact some insurance companies are providing premium rebates to their policy holders. Therefore, there is no justification for a premium increase. Instead, premiums should be reduced. An insurance company should not be rewarded for gross mismanagement which would clearly be the case if they require a premium increase under the current circumstances.

Every year GHI/Emblem Health raises the rates far beyond standard cost of living increases, and at the same time takes away services, increases deductibles- decreasing the value of the plan. They can't have it both ways. The rate should not be increased by more than 1.6%, which is what the government determined is the cost of living increase for 2020. Thank you!

The health insurance policies through the NY State of Health Marketplace are already extremely expensive. The jump between the cost of the Essential Plan and the next level of insurance plans is insane in relation to the income requirements for each. Please, please don't increase the cost of this plan, especially right now. Many of us who are on marketplace insurance are gig workers who have been adversely affected by COVID-19. We are unemployed, and are unsure when that will change. The last thing we need is for our healthcare costs to become that much more of a burden.

My health insurance company is not on your list -- it's Emblem Health. The dramatically increasing insurance premiums each year make it impossible for me to have continuity of care. I switched insurance providers in 2019 because my monthly insurance bill was going to increase by $70 or 9% without any change in the the services I could access. Now that I am on another plan with another insurer, I cannot see any of the physicians I had seen for years. With the proposed rate increase, I will be forced again to shop for another, more affordable insurance provider. Please consider the hardship these costs and limitations place on working people. We all need access to consistent, affordable care.


The individual plan rate increase is above 9%. The members of these plans are already paying an exorbitant monthly premium with many paying over $800 per month. The proposed rate increase in not even inline with what EmblemHealth released in their expected expense increase. They projected that their expenses will increase by 8.5%: (https://www.emblemhealth.com/content/dam/emblemhealth/pdfs/Employers/Resources/2021/Ind_Prior_Approval_Narrative.pdf). In additional, EmblemHealth has not released a detailed accounting of how or why they anticipate their expenses will increase, simply a general statement. This proposed rate increase is putting a unjustified burden on the policy holders.

I am writing to object to the 9.5% increase EmblemHealth plan (aka HIP of Greater New York) is requesting for my plan. Every year our premiums are raised while our benefits shrink. Emblem always tries to curtail preventive care. For instance, I last year and my GP wrote a prescription for physical therapy. Emblem refused to cover it, arguing that physical therapy was covered only after a hospital stay. This is crazy since physical therapy would help *prevent* costly surgery. Emblem covers occupational therapy but I was told that applies only for hands, not . So I paid for physical therapy out of pocket, bypassing the insurance. Of course this was on top of our monthly premiums. It's almost impossible to find a specialist or dentist that accepts Emblem in our neighborhood. My spouse and I pay $1,327.36 a month in premiums. This is very high and another 9.5% would make it even more difficult for us. Finally, communication with Emblem is difficult as you get different responses depending on which operator you speak to. I do not think they deserve to be able to hike their rates to such an extent. Sincerely,

I am absolutely disgusted that EmblemHealth would have the gall, in the midst of a global pandemic, to dream of increasing their premiums!! And by 9.5%! My wife and I are both unemployed as a result of the pandemic. Have you no morals?! This disgusting show of greed and unharnessed capitalism goes against the humanity and empathy a national crisis should bring out in all of us.


Is crazy what the cost of insurance is. You can't even get an appointment. Waited 5.5 months for an appointment for a physical and was cancelled due to covid 19. Still most doctors are only doing telemedicine visit, is crazy that I pay $650 amonth to not even be able to go to the doctor and able to get lab work that is needed. Plus you can't even see the doctor you want because doctor/nurse practictioner not in the plan. Truthfully I should get a money back the last 2 years literally will only have had one visit each year for GYN visit. Is disgraceful how healthcare work. The only ones making money are the insurance providers and it is going to go up almost 10%. I don't mind paying a reasonable amount but the cost monthly plus that includes $5900 deductible and you can't even get an appointment for a physical and you can't see the provider you want is just disgraceful.

Hello, I just received a letter from my insurance company Emblem notifying us that they are requesting an increase. We do not support this . My wife and I pay this ourselves and it is already way to high. We can't even write it off on our taxes . This is way out of order ! These insurance companies have plenty of money to run their operations. The government has to step in and control this . Also , we are coming out of this covid thing and alot of people are trying to get back on their feet. God Bless,

My hios plan id # is 88582ny1080001. I clicked on GHI, but i really am on the Emblem HIP plan which his NEVER on the dropdown option (maybe that's why the rates go up insanely every year, no option to protest Emblem). As a 1099, I have no option to buy into health insurance through a group. I looked into the marketplace but not 1 of my doctors took it. Therefore, I have no choice but to pay these sick prices which go up ridiculously every year. I am currently unemployed since March !7, 2020. How will I ever be able afford a 9.40% increase if you allow these money hungry insurance companies to rip us off every year? I'm sure I am 1 of the many Americans who are earning an honest living but are being choked by being unemployed and seeing these rising costs of health insurance. You guys have got to stop this greed and let us middle class have basic coverage without raising us so much each year. I don't get any where the raises that the insurance companies get, so why such high increases? STOP THE THIEVES NOW!!!!

I get my health insurance via the Marketplace (I'm a writer and a freelancer). I make *just* above the cutoff (my adjusted gross income is about $34K a year but my total income is over $47K). I have an individual policy from Emblem Health and it is VERY VERY tough for me to pay my premiums, which this year are about $685 a month (with a $6700 deductible). I'm a health person, thankfully, but have insurance so I can have yearly checkups and in case I get sick. I justgot a letter that even though we're in a pandemic with no one working, massive unemployment and a pandemic, once again Emblem is hoping to raise their rates for premiums to 9.5%. This is UNCONSCIONABLE! For the first time in my life, I am considering going without health insurance which is insane during a pandemic. I am URGING you to deny this increase. The insurance already barely covers anything (without it being subject to a deductible--if I have to take an ambulance to the ER, it'll cost me $6700--my deductible--for example. PLEASE DENY ANY HEALTH INSURANCE RATE INCREASES DURING THE PANDEMIC AND FOR 2021.


FYI

From: Sent: Tuesday, June 30, 2020 11:32 AMTo: dfs.sm.Consumers <[email protected]>Subject: Premium rate increase

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

NYS Department of Financial Services

Health Bureau - Premium Rate Adjustments

One Commerce Plaza

Albany, NY 12257

June 29, 2020

Dear Sir/Madam:

My health plan is with Emblem Health it is an individual health plan.

HIOS Plan ID: 88582NY1960001


I received a letter from Emblem Health that they are filing a request with your office (DFS) to approve a premium rate increase for 2021.

In January of 2020 I had to change my health plan to a less desirable one because I could not afford the premium. Now that I can finally manage the cost of my policy, Emblem Health plans to raise it.

My place of business had to close on May 16, 2020 and is not planning to open until September 2020, because of COVID-19. So economically speaking a premium raise would be a hardship for many people out of work who are still playing catch-up with bills.

I beseech you not to approve this raise.

Thank you in advance for your consideration in this matter.

Respectfully yours,

Address not foundYour message wasn't delivered to dfs.ny.gov/consumers/health_insurance/[email protected] the address couldn't be found, or is unable to receive mail.LEARN MOREThe response was:550 5.1.1 The email account that you tried to reach does not exist. Please try double-checking the recipient's email address for typos or unnecessary spaces. Learn more at https://support.google.com/mail/?p=NoSuchUserd142sor1827279iof.93 - gsmtp


---------- Forwarded message ----------From: To: emblemhealth.com/[email protected]: dfs.ny.gov/consumers/health_insurance/[email protected]: Date: Mon, 29 Jun 2020 22:18:14 -0400Subject: Premium rate increase

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From: Sent: Tuesday, June 30, 2020 12:01 PMTo: dfs.sm.Consumers <[email protected]>Subject: Premium rate increase




One Commerce Plaza

Albany, NY 12257

June 29, 2020

Dear Sir/Madam:









Respectfully yours,


From: Sent: Tuesday, June 30, 2020 12:01 PMTo: dfs.sm.Consumers <[email protected]>Subject: Premium rate increase




One Commerce Plaza

Albany, NY 12257

June 29, 2020

Dear Sir/Madam:









Respectfully yours,


To the Dept. of Financial Services - Health Bureau - Premium Rate adjustment My Insurer is: EmblemHealth (underwritten by HIP Health Plan of NY) [I have EmblemHealth Select Gold D Insurance as an individual member. My HIOS Plan ID number is 88582NY1140001 ( my member ID # is ) ] I am writing today about the proposed rate increase for Emblem Health for 2021. It would absolutely be a hardship - to such an extent that I am thinking it highly unlikely that it would be possible for me to remain with the Emblem company. I believe These rate increases should be rejected - We keep paying more, while many of us are earning far *less, and while nearly all of us are at higher risk this year many of us are getting less help from our insurance company. (Even help we are entitled to is not always mentioned when we inquire from the health insurance customer service what is covered. Some of the people there are wonderful but some are acting like gatekeepers who are protecting something else more than their customers health). While I am grateful for the many skilled and caring doctors and other medical professionals who have helped us who are part of the network covered by Emblem underwritten by HIP, when rates and deductibles go up and coverage goes down, real care and theoretically “wonderful” or even basic good health care may not be usable, as it may become out of reach. I am sure I am among a large number of the patients/Health Insurance Plan - Emblem members who do not expect to find it easy to earn a lot for the expenses of the coming year, surely not expecting to be able to come up with more than $1000 beyond this year’s premium charges to keep my insurance, what with obligations related to this year including (not only my recent injury but) the complications of the slowdowns and shutdown and special needs for safety and daily needs related to the way our communities have been affected by COVID. If anything it is a time when a rate decrease would be better. Currently not only do I think that i do not have enough money to continue with Emblem with such a rate increase but I am writing to protest it and ask: Why they would ask for a rate increase at a time when they know that many of their patients, likely most of their patients, have had large expenses and great decreases in intact workplaces, or other work opportunities due to the situation with the plague of COVID in our country ( world)? Anyhow I hope you will be well and that all the patients and providers of the care will see improvements and good days the remainder of this year and the one ahead, but this is not the time for a rate increase. Sincerely,

I am writing regarding a proposed health insurance rate increase from Emblem Health. I am requesting that you NOT approve a rate increase. I have been a member with EmblemHealth since 2017. When I enrolled, I was paying slightly over $600/mo for the best coverage they offered. In 2018 I had to drop to lesser coverage as the cost went up for that level. Even with the drop to lesser coverage, there was an increase in monthly cost. I have kept that lesser coverage since then and, in 2020, I am paying almost $900 for that same coverage. The past 2 years have come with double digit percentage (and TRIPLE digit dollar) increases. This is getting ridiculous! My premiums have gone up $300/mo and I’m not getting anything better. In fact, I’m getting more restrictive coverage. On IRS Form 990 from 2016, Karen Ignagni, CEO of EmblemHealth, is reported to have been paid a salary in excess of $2.4 million. One must assume her salary has gone up since then. How is EmblemHealth a “nonprofit” when they pay their CEO that much? At what point do we say “enough is enough”? For me, that may be next year or, depending on the rate of increase, 2022 at the latest. I cannot afford to keep paying more and more and getting less and less. So I am asking that you deny EmblemHealth their requested rate increase for 2021. Thank you.


I fully appreciate that insurance companies are struggliing against the continued efforts to eviscerate the Affordable Care Act by the party now in power. By the same token, health insurance is one of the largest industries in the country, and I have seen no evidence that they are working against the erosion of the act. I'd like to see my insurer use a more community minded approach to managing costs, where raising rates has a place alongside advocacy for broad-based coverage and public education about implications of dismantling the current system. At some point, insurance will become unaffordable to nearly everyone. The proposed increase is excessive, unrelated to inflation and greedy.


Please see https://hcfany.org/resources/comments-on-emblems-2021-rate-request/ for our full comments including information about the rest of New York's individual market requests. The Health Insurance Plan of Greater New York (Emblem) is a non-profit health insurance carrier that operates in all nine of New York’s rating regions. Its members have a slightly worse morbidity than the rest of the state – the plan expects to receive 7 percent of its individual market premium revenue from the federal risk adjustment program. Emblem is the third most expensive plan in New York’s individual market and was approved for the highest rate increases in New York’s individual market in 2019 (17 percent) and 2020 (14 percent). After the 2018 rate increase, Emblem’s membership declined by 11 percent; after the 2019 rate increase it lost a further 16 percent of its members and now has just about 16,000. It is likely these large price increases rendered Emblem’s products unaffordable for many of its members. Membership may also be declining for Emblem because it performs below average on most indicators in the Department’s 2019 Consumer Guide to Health Insurance. Emblem’s HMO is second to last in the state for customer complaints filed with the Department, and the Department ruled against the plan in 58 percent of those complaints. Emblem’s members file large numbers of internal and external appeals, in which Emblem reverses its original decisions in 48 percent and 26 percent of the time respectively. Emblem’s members rank the plan as significantly below average on all measures of access to care, including getting needed care. Members seem to have an especially difficult time accessing preventive care for adolescents, immunizations of all types, breast cancer screenings, postpartum care, and care needed to manage diabetes. The Department tracks these measures because of their importance for overall public health; Emblem’s failure on so many public health issues is alarming. Further, Emblem’s members are unsatisfied with the providers they have access to through Emblem’s networks. For 2021, Emblem is requesting another large increase of 9.5 percent. This is below the average 11.8 percent requested by New York’s carriers but still a burden for consumers, especially after several years of very high rate increases and during the economic downturn. HCFANY has identified numerous areas in Emblem’s rate application that present opportunities to lower the request. These include its low projected medical loss ratio for 2021, its high expectations for medical trend, its high administrative costs, duplicative requests, high profit request, and its requests related to COVID-19. The Department should deny Emblem’s request and consider reducing its 2021 rates. A. Emblem is projecting a low medical loss ratio of 84.7 percent for 2021 Emblem’s MLRs have been high in the past –107.5 percent in 2017, and 98.5 percent in 2018. However, the large rate increases Emblem received since then lowered its MLR to 87 percent in 2019. In 2021, Emblem is projecting an MLR of 84.5 percent, which is close to the State’s 82 percent minimum requirement. In its application for an increase in their 2020 rates, it anticipated an even lower MLR of 83.1 percent. Emblem is already one of the most expensive plans offered in New York’s individual market. The large rate increases awarded to Emblem for the past few years have presented hardships for Emblem’s members and resulted in membership declines. On behalf of New York’s health insurance consumers, HCFANY urges the Department to require Emblem to project a higher target MLR next year to protect its members from another large rate increase. B. Emblem is expecting high medical trend for 2021 of 8.6 percent, despite enrollee complaints about limited access to health care Emblem’s expectation for an 8.6 percent medical trend is higher than the average request in New York’s individual market and higher than its previous trend rates for the third year in a row. In fact, Emblem’s actuaries assume the second highest medical trend in the individual market for 2021. Emblem’s exhibits provide no justification for its trend or explanation for why it believes medical trend will be significantly higher in 2021 than it was last year. Sometimes there is a trade-off for consumers between high premiums and better access to care, for example through larger provider networks. In Emblem’s case, its members pay some of the highest rates in New York yet struggle to access basic health services. Plans with much lower rates have members that report more satisfaction with their providers and with access to care – and more success in meeting the State’s public health goals. The Department should demand better access to preventive care for Emblem’s members. It should also require Emblem to control its medical costs to reflect its members limited access to care. C. Emblem should lower its administrative costs before asking consumers for another large premium increase Emblem is projecting that 13.3 percent of members’ premiums will be used for administrative costs. This is a decrease from 14.9 percent last year – but it is still higher than the average for other plans


and too high for consumers. There are plans in New York that are better at controlling administrative costs. For example, MetroPlus anticipates spending just 8.3 percent of premiums on administrative costs. HealthPlus and UnitedHealthcare of New York anticipate spending only 9 percent and 9.5 percent respectively on administrative costs. As one of the largest carriers in New York State, Emblem should be held to the standard of those plans that are the most successful at controlling administrative costs. One area Emblem might look to control administrative costs is its high reversal rates for customer complaints and appeals. As mentioned above, Emblem’s decisions were reversed in 58 percent of the complaints its customers filed with the Department and the carrier reverses its own decisions in 48 percent of internal appeals. It is laudable that Emblem’s members are able to fix these mistakes, but Emblem should improve its original decision-making to save itself – and its members – from embarking on time-consuming and costly appeals processes. D. Emblem is asking for a duplicative increase for the loss of federal cost-sharing reduction payments and the removal of the individual mandate penalty Emblem is asking for a 0.66 percent rate increase to make up for losing federal cost-sharing reduction payments and continues to claim that the removal of the federal individual mandate penalty will degrade its risk pool. However, both of these conditions have been accounted for during previous rate increases granted to Emblem in years past. Similarly, increased costs for the carrier of cost-sharing reductions or pediatric dental benefits should not compound year after year – after those benefits are incorporated in the premium once, medical trend adjustments should cover increases in the costs of providing the benefits. It is especially unfair for Emblem to claim that the loss of the individual mandate penalty will worsen its risk pool, when it is an expensive plan that provides poor service to members. Likewise, past prophesies about New York’s individual market entering a death spiral have failed to materialize. In reality, Emblem’s enrollment decline is due to the fact that it continues to ask for, and receive, inappropriate and unaffordable rate increases - not because New York’s individual market is degrading in general. The Department should not approve duplicative rate increases without explanations for why previous adjustments were miscalculated. E. Emblem is asking for an unusually high surplus of 2 percent Emblem is one of only four carriers proposing a surplus of 2 percent or more. Most carriers have maintained a surplus of 1.5 percent or less. Given that Emblem’s goal is a low MLR and that it is not controlling its administrative costs or medical trend, HCFANY respectfully urges the Department to disallow a 2 percent surplus. F. Emblem is asking for a 2 percent increase related to COVID-19 when it should not get any COVID-19 increase As described above, HCFANY believes that carriers should not receive any increases as a result of speculation about hypothetical health care utilization, treatments, and vaccine development in 2021, especially in the middle of a financial downturn when consumers are suffering economically. For example, Emblem is one of the plans anticipating vaccination costs despite the fact that there is no COVID-19 vaccine. In addition, given the low utilization in 2020, all reserves that have been accrued should be spent on lowering enrollees’ premiums for 2021.

Why should my premium go up when I have not been able to use the insurance? Doctor offices have been closed since March and are barely starting to open up. Many offices are still closed. Thousands of people are out of work completely, including me. And this company has the audacity to ask for a rate increase! What nerve! How about instead of giving this insurance company an increase – you make the company lower their rates to help out the consumer who have been financially effected by this global pandemic. DO NOT GIVE THEM 1 PENNY OF WHAT THEY ARE ASKING FOR!!!!


I am concerned about this unprecedented rate change due to the fact that during this COVIDs crisis, I have been unable to even utilize my full-rate $650/mo health plan for even a routine check-up. As it stands, I have never made any claims via EmblemHealth, and as such, the proposed 9.50% premium seems exorbitant and absurd. I can understand premiums increasing for specific individuals who are diagnosed with COVID-19 etc, but there appears to be little legitimate basis for a rate hike of that magnitude to be universally applied especially for those of us who have not in any way benefited from enrollment in our health plans. Best regards.

I am writing about the proposed 9.5% rate increase on my health insurance premium with Emblem Health through NY State is Health marketplace. I use the bare minimum of services each year, which would be cheaper to pay for out of pocket, my deductible is outrageous ($5,900 a year) and my plan doesn’t cover any emergency care. Since I have been on unemployment and many people have lost their jobs, job security, and income since the Covid-19 pandemic started in March, I think I speak for all New Yorkers when I say we can’t afford an increase! The federal and state have been providing a lot of financial support for testing and therefore reducing the costs for major medical insurances and it is completely inappropriate that Health Insurance Plan of Greater New York is taking advantage of millions of New Yorkers already suffering from financial stress by raising their premium almost 10%. I am curious to know who will this benefit? Likely the high level executive’s salaries, unlikely us as policyholders.

Health Insurance Plan of Greater New York Individual 2021 ... · Thank you. recieved letter from...

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