MARKET STABILITY WORKGROUP - HealthSource RI · Source: 2019 OHIC Small Group Rate Review Template...

MARKET STABILITY WORKGROUP

Tuesday, May 30, 20188:00 – 10:00 a.m.

The Institute for the Study & Practice of Non-Violence

ADDRESSING FEEDBACK FROM PREVIOUS SESSIONS

2

• Draft Report was shared

• Analysis (corrected doc) was shared concerning the impact of reinsurance on low-income, subsidized enrollees. Any questions on what was sent?

3

Topic(s) for Discussion Meeting DateMeeting 1

Introductions + Setting the StageWednesday, April 18

Meeting 2 What has been accomplished + What is at risk in RI

Wednesday, April 25

Meeting 3National Survey of State Actions + Considerations

Tuesday, May 1

Meeting 4Policy Deep Dive: the “carrot” approach

Tuesday, May 8

Meeting 5Policy Deep-Dive: the “stick” approach

Tuesday, May 15

Meeting 6Regroup on Package of Policy Options + Begin

Discussion of RecommendationsTuesday, May 22

Meeting 7Overview of Factors Influencing Premiums + Moving

Towards Final RecommendationsTuesday, May 29

Meeting 8Reaching Final Recommendations

Tuesday, June 5

RI MARKET STABILITY WORKGROUP: EIGHT WEEK SYLLABUS

4

Purpose of Today’s Meeting

• Provide an initial look at 2019 proposed rates, including market context over time and impact to customers

• Review the draft report and address open questions

• Gauge consensus on recommendations and identify pathway to finalization

Today, we ask that you

• Answer or confirm particular items in the draft report

• Offer any other feedback about the draft report

• Keep in mind that due to rate hearing rules, specifics of rate filings cannot be discussed when Commissioner Ganim is in the room

TODAY’S AGENDA

5

1. 2019 Initial Rate Filings overview

2. Review of Draft Recommendations

TODAY’S AGENDA

PRELIMINARY 2019 RATE

REQUESTS

Presentation | May 29, 2018

Cory King, Principal Policy Associate

Office of the Health Insurance Commissioner

A Few Preliminary Remarks

1. The rate filing information presented today reflects

proposed rates to be charged in 2019. OHIC will review

the proposals and determine whether to approve,

modify, or reject them.

2. OHIC’s final approval will be announced by August 1st.

3. Pursuant to RIGL § 27-19-6 & § 27-20-6 the BCBSRI

individual market rate filing will be subject to an

hearing under the APA. 7

Standards of Rate Review

OHIC evaluates whether an insurer’s proposed rates are “consistent

with the proper conduct of its business and with the interest of

the public” based on three key standards:

1. Solvency and actuarial soundness – are rates sufficient to ensure

the solvency of the insurer and based on sound actuarial

principles?

2. Consumer protection – Would consumers receive adequate

contractual benefit in exchange for the proposed premium?

3. Health insurer policies to improve affordability, quality and

accessibility of medical care.

8

Reviewing Commercial Health Insurance Rates -

Consumer Savings

$0.0

$10.0

$20.0

$30.0

$40.0

$50.0

$60.0

$70.0

2012 2013 2014 2015 2016 2017

DIFFERENCES BETWEEN REQUESTED AND APPROVED RATES, 2012-2017 (Review Year)

Year

Mill

ion

s o

f D

olla

rs

▪ Since 2012, OHIC’s

rate review has

saved Rhode Island

consumers $235.7

million

▪ The RI commercial

market comprises

about 220,000

enrollees.

9

10

▪ Rate review is a largely prospective exercise.

▪ There is a significant lag between data and rate effective date (2

years).

▪ For rates effective 1/1/2019, we review CY 2017 claims data and

prior.

Jan 1, 2019 Rates1

May 15, 2018 Filing1

CY 2017 Data & Trends

Claims Trends & Rate Increases

Individual Market Rate Changes

The Overall Weighted Average Rate Change represents adjustments to reflect the benefits in plans, including modifications to prior year benefits and pricing and it includes terminated plans. This weighted average rate increase represents the average rate that consumers will experience. It does not include the effect of changes in age.

The EHB base rate is used by OHIC to compare premiums across insurers and years and represents the monthly average rate for a hypothetical plan with no cost-sharing for a 21-year old for a given insurer in a given market. Essential Health Benefits are a set of benefits that must be covered by plans, as called for in the Affordable Care Act.

2018 rate increases shown above do not include the effect of the Trump Administration’s decision to stop cost sharing reduction (CSR) payments.

2016

Approved

2017

Approved

2018

Approved

2019

Proposed

BCBSRI 3.8% 5.9% 12.1% 10.7%

NHP 5.8% -5.9% 5.0% 8.7%

UHC 2.7%

Market Weighted Average 4.5% 1.6% 9.4% 9.7%

BCBSRI 10.4% 4.7% 10.6% 14.2%

NHP 8.0% -9.8% 2.4% 14.6%

UHC 4.1%

Market Weighted Average 9.3% -0.6% 7.5% 14.4%

Overall Weighted Average Change

EHB Base Rate Change

11

Impact of Individual Mandate Penalty Repeal (Carrier Proposed)

12

$200

$250

$300

$350

$400

$450

$500

$550

$600

2018 2019

$370$403

+6.9% ($26)

+1.9% ($7)for mandate repeal

$200

$250

$300

$350

$400

$450

$500

$550

$600

2018 2019

$531 +11.1% ($59)$590

Neighborhood Health Plan (NHP)

8.8% Exchange enrollment-weighted increaseIncludes a 1.9% premium increase due to repeal of mandate penalty.

Blue Cross & Blue Shield RI (BCBSRI)

11.1% Exchange enrollment-weighted increaseIncludes no adjustment for repeal of the mandate penalty.

Exchange Average Full Premium pmpm (as Proposed)

“Repeal of the mandate penalty will result in approximately 1.9% increase of premiums, assuming healthy individuals will no longer purchase health insurance.” – NHP Filings

“BCBSRI is not including an adjustment to reflect any potential change to the overall morbidity of the Individual population resulting from the elimination of penalties.” - BCBSRI Filings

Small Group Market Rate Changes

The Overall Weighted Average Rate Change represents adjustments to reflect the benefits in plans, including modifications to prior year benefits and pricing and it includes terminated plans. This weighted average rate increase represents the average rate that consumers will experience. It does not include the effect of changes in age.

2016

Approved

2017

Approved

2018

Approved

2019

Proposed

BCBSRI 2.3% 3.6% 7.3% 5.7%

NHP 1.9% -3.1% 6.3% 0.0%

Tufts HMO 3.3% 0.8% 6.0% 10.9%

Tufts PPO 3.7% 1.0% 6.5% 10.1%

UHC HMO 7.2% 0.4% 8.1% 3.4%

UHC PPO 7.2% 0.1% 8.1% -0.6%


13

Large Group Market Rate Changes

The Expected Overall Average Premium Increase represents the average expected percentage change in premiums from one year to the next, holding benefits constant, across all employers that are up for renewal within a given market. It is weighted by employer size. This average expected premium increase is comprised of rate factors that are applied to the employer’s existing experience.

2016

Approved

2017

Approved

2018

Approved

2019

Proposed

BCBSRI 5.1% 7.0% 10.5% 10.6%

Tufts HMO 6.1% 4.8% 9.8% 10.3%

Tufts PPO 6.6% 4.3% 10.4% 10.2%

UHC 4.4% 3.6% 8.0% 9.1%


14

Market Stabilization Workgroup Meeting 7: Underlying Trends and Customer impact

May 29, 2018

15

2019 Rate Filings Analysis

16

1. Early Warning Signals Are there signs of market destabilization so far - in the rate filings as proposed by the carriers?

2. Customer ImpactsWhat are the implications of these rate increases for specific subgroups and populations?

Base Data: Signs of Individual Market Destabilization?

412,070

482,336 524,323 509,619

CY 2014 CY 2015 CY 2016 CY 2017

17

Individual Market Member Months (NHP and BCBS Combined)

Change: 17% 9% -3%

Source: 2019 OHIC Individual Rate Review Template Part 1, Tables A2 and A3

$425

$395

$413

$449

CY 2014 CY 2015 CY 2016 CY 2017

Individual Market PMPM Costs(Allowed, includes member cost sharing, NHP and BCBS Combined)

Change: -7% 4% 9%

• Troubling increase in underlying trend• Key Drivers: hospital (+12%), Rx (+12%)• Projected “population risk morbidity”

• First post-ACA decline• May indicate risk pool degradation

Base Data: Signs of Small Group Market Destabilization?

18

Source: 2019 OHIC Small Group Rate Review Template Part 1, Table A2 & A3

$437

$451

$461

$485

CY 2014 CY 2015 CY 2016 CY 2017

Small Group Market PMPM Costs(Allowed, includes member cost sharing, NHP, BCBS, Tufts and United Combined)

Change: 3% 2% 5%

854,212

752,130 701,536

668,575

CY 2014 CY 2015 CY 2016 CY 2017

Small Group Market Member Months (NHP, BCBS, Tufts and United Combined)

Change: -12% -7% -5%

Modest underlying cost trendsContinued and troubling declineIncreasing destabilization

BCBS Off Exchange12,504

BCBS On Exch

2,065

NHP On Exch3,234

BCBS On Exchange6,969

NHP On Exchange19,800

Individual Market Impact

19

Unsubsidized Enrollment 40% 17,803

Subsidized Enrollment 60%26,769

*Calculated using age 48 for each plan. Younger ages will see more moderate decreases/increases, older ages will see more dramatic decreases/increases

†Inclusive of below categories. I.e. “Greater than $5” includes “Greater than $20.”

Plan Categories by Rate Increase for 48 year old*

% of HSRI Customers in these plans

Rate Decrease 11.0%

$0-$5 53.5%

Greater than $5 31.9%†



Greater than $50 4.6%

Customer Scenarios

20

* Example based on a household with 4 members, ages: 56, 50, 23, and 17** Example based on a household with 2 members, ages: 56, and 50

Unsubsidized Family of four*$100K HH income 407% FPL

Neighborhood PLUS (Gold) $1,407 $16,884 $1,518 (+7.9%)

$18,220 (+7.9%)

Blue Solutions for HSA Direct 6000/12000 (Bronze)

$1,294 $15,526 $1,418 (+9.6%)

$17,017 (+9.6%)

(1)

Customer Most Popular Plans 2018 2019 Proposed

Monthly Annual Monthly Annual

Subsidized Family of four*$65K HH Income 265% FPL

Neighborhood COMMUNITY (Silver) $371 $4,446

$390 (+5.2%)

$4,675 (+5.2%)

Blue Solutions for HSA Direct 4100/8200 (Silver) $762 $9,148

$867 (+13.7%)

$10,400 (+13.7%)

(2)

(3)

Subsidized Couple**$23.5K HH income 145% FPL

Neighborhood COMMUNITY (Silver)

$3 $39 $7 (+112.8%)

$83 (+112.8%)

Blue Solutions for HSA Direct 4100/8200 (Silver) $313 $3,761

$391 (+24.7%)

$4,689 (+24.7%)

DISCUSSION

21

THE CHARGE TO THE WORKGROUP

Rhode Island has been here before.In response to the passage of the ACA, our state pulled together a coalition of experts.

Those efforts resulted in providing access to high-quality, affordable health coverage to more Rhode Islanders than ever before.

In 2018, continued efforts are needed to protect that success – for Rhode Island’s individuals, families and business community.

Guiding Principles:1. Sustain a balanced risk pool;

2. Maintain a market that is attractive to carriers, consumers and providers; and

3. Protect coverage gains achieved under the ACA.

Goal: Identify and propose sensible, state-based policy options for RI that will be in service to those Principles.

22

SHARED RESPONSIBILITY REQUIREMENT

A state-based shared responsibility requirement : To mitigate the impact of the federal health insurance mandate penalty repeal, Rhode Island should implement a state-level shared responsibility requirement. For the sake of continuity and simplicity, a requirement should be implemented as soon as practicable and with broad-based support and should use the federal structure as a basis. Any funds raised through the implementation of a shared responsibility requirement should be primarily designated for initiatives aimed at protecting the affordability of health coverage. -MSW Draft Report.5_25_18 p2

In meeting 5, there was consensus that a state-based shared responsibility requirement is consistent with the guiding principles of the Workgroup.

Does the Workgroup support this recommendation?

Consider alternative text here:“should mirror the federal structure.”

23

FURTHER ACTIONIn addition to the above policy recommendations, the Workgroup

acknowledges that further work remains. The Workgroup therefore

recommends the following:

▪ Future action required: Rhode Island should focus next on how to fund a

state reinsurance program and how to best design and implement a

shared responsibility requirement. Additionally, further efforts must be

made to address the particulars of the aforementioned affordability

initiatives, including the impact of recommendations on low-income

Rhode Islanders and whether any further action is necessary to address

this population.

The Workgroup notes that while time is of the essence, carriers setting rates

for the 2020 coverage year can still consider actions taken during the 2019

legislative session. This work should begin without delay and should be

undertaken with participation from the legislative and executive branch.

-MSW Draft Report.5_25_18 p2

In meeting 6, the Workgroup was in general agreement that further work remains and that it needs to be discussed and deliberated on prior to 2020 rate setting.

Does this Workgroup support this recommendation?

24

REINSURANCE VIA 1332 WAIVER

A 1332 Waiver under the ACA to implement a reinsurance

program: The state should be authorized to submit a 1332 waiver

request as provided for under the ACA to implement a state

reinsurance program. The state reinsurance program should be

designed to mitigate premium increases in the year 2020 and

beyond. The Workgroup acknowledges that 1332 waiver

applications require a stakeholder review process and notes that

any state funding necessary to operate a reinsurance program

would require future legislative action. -MSW Draft Report.5_25_18 p1

In meeting 6, the group largely supported this recommendation.

Does this language accurately reflect the recommendation of the group?

25

SHORT-TERM LIMITED DURATION PLANS

State authority to regulate Short-Term Limited

Duration (STLD) health plans : OHIC should be

provided with regulatory oversight authority of

STLD plans to ensure such plans are subject to the

same consumer protections that apply to all other

private health insurance coverage offered for sale in

the state. -MSW Draft Report.5_25_18 p1

In meeting 6, the Workgroup voted to provide unanimous support for this recommendation.

Does this language accurately reflect the recommendation of the group?

26

OTHER RECOMMENDATIONS OR COMMENTS?

Are there any other recommendations not included that should be considered today for inclusion in this package?

Are there any comments on the Discussion and Findings section?

Comments on the Discussion and Findings section can also be emailed to [email protected] by end of day on Thursday, May 30

27

PACKAGE OF RECOMMENDATIONS

28

Does the Workgroup Support the package as it stands?

PUBLIC COMMENT?

29

THANK YOU

APPENDIX

31

PRELIMINARY 2019 RATE

REQUESTS - APPENDIX

Presentation | May 29, 2018

Cory King, Principal Policy Associate

Office of the Health Insurance Commissioner

2016 2017 2018 2019

BCBS 3.8% 5.9% 12.1% 10.7%

NHP 5.8% -5.9% 5.0% 8.7%

UHC 2.7%

3.8%

5.9%

12.1%

10.7%

5.8%

-5.9%

5.0%

8.7%

2.7%

-8.0%

-6.0%

-4.0%

-2.0%

0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

12.0%

14.0%

WEI

GH

TED

AV

ERA

GE

RA

TE IC

HA

NG

EINDIVIDUAL MARKET

WEIGHTED AVERAGE RATE CHANGE Proposed Increase

33

2016 2017 2018 2019

BCBS 10.4% 4.7% 10.6% 14.2%

NHP 8.0% -9.8% 2.4% 14.6%

UHC 4.1%

10.4%

4.7%

10.6%

14.2%

8.0%

-9.8%

2.4%

14.6%

4.1%

-15.0%

-10.0%

-5.0%

0.0%

5.0%

10.0%

15.0%

20.0%

EHB

BA

SE R

ATE

CH

AN

GE

INDIVIDUAL MARKETEHB BASE RATE CHANGE Proposed Increase

34

2015 2016 2017 2018 2019

BCBS 5.2% 2.3% 3.6% 7.3% 5.7%

NHP -1.8% 1.9% -3.1% 6.3% 0.0%

UHC HMO 9.6% 7.2% 0.4% 8.1% 3.4%

UHC PPO 9.6% 7.2% 0.1% 8.1% -0.6%

Tufts HMO 4.5% 3.3% 0.8% 6.0% 10.9%

Tufts PPO 4.7% 3.7% 1.0% 6.5% 10.1%

-4.0%

-2.0%

0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

12.0%

WEI

GH

TED

AV

ERA

GE

RA

TE IC

HA

NG

ESMALL GROUP MARKET

WEIGHTED AVERAGE RATE CHANGE Proposed Change

35

2016 2017 2018 2019

BCBS 5.1% 7.0% 10.5% 10.6%

Tufts HMO 6.1% 4.8% 9.8% 10.3%

Tufts PPO 6.6% 4.3% 10.4% 10.2%

UHC 4.4% 3.6% 8.0% 9.1%

0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

12.0%

EXP

ECTE

D A

VER

AG

E R

ATE

CH

AN

GELARGE GROUP MARKET

EXPECTED OVERALL AVERAGE RATE CHANGE Proposed Increase

36

Market Stabilization Workgroup Meeting 7: Underlying Trends and Customer impact

May 29, 2018

APPENDIX

37

Individual Market Trends

6.9%

4.8%

6.8% 6.6%

5.3%

9.3%

Pop RiskMorbidity

InpatientHospital

OutpatientHospital

Primary Care OtherMedical/Surgical

Prescription Drug

38

Projection Adjustment Factors for 2019 Rate Filings(NHP and BCBS Combined)

Source: 2019 OHIC Individual Rate Review Template Part 2 Rate Development

Individual Market Trend Detail

$413

$10$7

$11$8

$449

$300

$320

$340

$360

$380

$400

$420

$440

$460

CY 2016Total Claims

InpatientHospital

OutpatientHospital

PrescriptionDrugs

OtherMed/Surg*

CY 2017Total Claims

39

Increase in PMPM Costs 2016-2017(Allowed, includes member cost sharing, NHP and BCBS Combined)

Percent Increase 2016-2017:

12% 7% 12% 7% 9%

❖ 9% increase in claims costs in the individual market from 2016-2017

❖ Almost 1/3 of the increase was due to increased inpatient costs

Source: 2019 OHIC Individual Rate Review Template Part 1, Table A2 & A3.

*Other Med/Surg also includes Primary Care and claims not otherwise categorized.

Exchange Enrollment Details

40

Exchange Unsubsidized Enrollments(5,299 Total, 17%)

Enrollment by plan and carrier, sorted most to least enrollments

Exchange Subsidized Enrollments(26,769 Total, 83%)

Enrollment by plan and carrier, sorted most to least enrollments

SortbyEnrollment

NHP2018IndividualMarketPlansUn-subsidized

EnrollmentMetalLevel

NeighborhoodPLUS 996 Gold

NeighborhoodINNOVATION 887 Bronze

NeighborhoodECONOMY 664 Bronze

NeighborhoodPRINCIPAL 340 Gold

NeighborhoodCOMMUNITY 185 Silver

NeighborhoodVALUE 162 Silver

Total 3,234

BCBS2018IndividualMarketPlansUn-subsidized


BlueSolutionsforHSADirect6000/12000WPD 565 Bronze

VantageBlueDirect1325/2650 367 Gold

BasicBlueDirect6450/1290WPD 324 Bronze

BlueSolutionsforHSADirect1400/2800 245 Gold

BasicBlueDirect2750/5500 197 Gold

BlueSolutionsforHSADirect4100/8200WPD 93 Silver

BlueCHiPDirectAdvance2300/4600 93 Gold

VantageBlueDirect4850/9700WPD 72 Silver

BasicBlueDirect4900/9800WPD 41 Silver

BlueCHiPDirect2300/4600 35 Gold

BlueCHiPDirect4800/9600WPD 33 Silver

Total 2,065

NHP2018IndividualMarketPlansSubsidized


NeighborhoodCOMMUNITY 7,713 Silver

NeighborhoodVALUE 5,646 Silver

NeighborhoodPLUS 3,002 Gold

NeighborhoodINNOVATION 1,990 Bronze

NeighborhoodECONOMY 874 Bronze

NeighborhoodPRINCIPAL 575 Gold

Total 19,800

BCBS2018IndividualMarketPlansSubsidized


BlueSolutionsforHSADirect4100/8200WPD 1,541 Silver

BlueSolutionsforHSADirect6000/12000WPD 800 Bronze

BlueCHiPDirect4800/9600WPD 1,407 Silver

BasicBlueDirect6450/1290WPD 653 Bronze

VantageBlueDirect4850/9700WPD 595 Silver

VantageBlueDirect1325/2650 554 Gold

BasicBlueDirect4900/9800WPD 429 Silver

BasicBlueDirect2750/5500 352 Gold

BlueCHiPDirectAdvance2300/4600 253 Gold

BlueSolutionsforHSADirect1400/2800 245 Gold

BlueCHiPDirect2300/4600 140 Gold

Total 6,969

HH Income: $100,000

Member Impact: Scenario 1: Unsubsidized Family of FourHousehold Income $100,000 per year

Premium

Medical Expense ↑ 9.6% vs. HH Income ↑ 2.5%

$17,017

$15,526

$14,358

$13,100

2019

2018

2019 Medical Expenses: % HH IncomePremium Only: 17%Premium + Max OOP: 31%

Blue Solutions for HSA Direct 6000/12000 (Bronze)

41

Neighbor-hood PLUS (Gold)

Max OOP

HH Income: $102,500

HH Income: $100,000

Premium

Medical Expense ↑ 7.9% vs. HH Income ↑ 2.5%

$18,220

$16,884

$11,114

$10,300

2019

2018


Max OOP

HH Income: $102,500

HH Income: $65,000

Member Impact: Scenario 2: Subsidized Family of FourHousehold Income $65,000 per year

Premium

Medical Expense ↑ 13.2% vs. HH Income ↑ 0%*

$10,400

$9,148

$10,368

$9,200

2019

2018


Blue Solutions for HSA Direct 4100/8200 (Silver)

42


Max OOP

HH Income: $65,000


*Note: The subsidized customer scenarios shown assume no increase in household income year over year due to the impact of household income on subsidy eligibility – subsidized customers with increased income would see little impact to medical expenses as % of income due to the corresponding decrease in subsidy

HH Income: $65,000

Premium


$4,675

$4,446

$14,358

$13,100

2019

2018

Max OOP

HH Income: $65,000

HH Income: $23,500

Member Impact: Scenario 3: Subsidized CoupleHousehold Income $23,500 per year

Premium


$391

$313

$1,296

$1,150

2019

2018


Blue Solutions for HSA Direct 4100/8200 (Silver)

43


Max OOP

HH Income: $23,500


*Note: The subsidized customer scenarios shown assume no increase in household income year over year due to the impact of household income on subsidy eligibility – subsidized customers with increased income would see little impact to medical expenses as % of income due to the corresponding decrease in subsidy

Premium


Max OOP

$83

$39

$4,932

$4,500

2019

2018 HH Income: $23,500

HH Income: $23,500

Reinsurance Impact to Subsidized Enrollees

44

Tax Credits (APTCs) Are Based on Premium Costs

APTC = $300

Customer pays

Affordable Amount = $200

Total SLCSP Premium = $500

• Affordable amount is determined by income and family size

• The Second-Lowest Cost Silver Plan (SLCSP) is used as the benchmark for APTC calculation

• APTC covers the difference between them

45

Increased Premiums on the SLCSP Create Dollar-for-Dollar Increases in APTC

APTC = $300

Customer pays



APTC = $400

Customer pays



• Customer pays the same amount after APTC, assuming same household and income

This year

Next year

46

Premiums Vary Across Plans

•APTCs can be used to help buy any plan

• If all plans increase by the same percentage:• Cheaper plans (mostly Silver or Bronze) increase by fewer dollars than the SLCSP

and the APTC• More expensive plans (mostly Gold or Silver) increase by more dollars than the

SLCSP and the APTC• The spread of costs across all plans gets larger

•Customer costs after APTC remain steady for the SLCSP, but vary for other plans• Generally increase for more expensive plans, reduce for less expensive plans

47

Reinsurance Impact on Subsidized Enrollees

• If a new reinsurance program partially or wholly offsets premium increases across all plans:• Both the increases and decreases for other plans are partially or wholly offset• Those in more expensive plans will see a moderated year-to-year increase• Those in less expensive plans will see a moderated year-to-year decrease

•Reinsurance is unlikely to increase anyone’s costs, year-to-year, but may moderate what would otherwise be a large reduction in costs

•See attached document for numbers using RI plans

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MARKET STABILITY WORKGROUP - HealthSource RI · Source: 2019 OHIC Small Group Rate Review Template...

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