Letter to Jennifer Hammer, Director of the Ilinois Department of Insurance - Protect Illinois Consumers From Trump Health Care Sabotage

Letter

Dear Director Hammer:

We write to urge you to stand with Illinois families by directing health insurance companies to bring transparency to their proposed premium increases and price their plans in a manner that shields consumers from unnecessary costs. We are concerned that the proposed 2018 premium rate increases for Affordable Care Act (ACA) compliant plans on the Illinois Individual Marketplace reflect the instability created by congressional Republican efforts to repeal the ACA and the Trump Administration's sabotage of the marketplace. The mission of the Illinois Department of Insurance is, in part, to "protect consumers by providing assistance and information," and we believe there are actions you can take--which other states have similarly done--to address these concerns and protect Illinois consumers. Yesterday, the Centers for Medicare and Medicaid Services extended the filing deadline to accommodate states adopting such consumer protections--we believe it is imperative that Illinois take advantage of this opportunity.

Republicans have led a campaign over the past seven years to repeal the ACA, including proposals to force one million Illinoisans to lose coverage and increase premiums or weaken benefits for even more families. Though the repeal effort collapsed in the Senate, the constant rhetoric stoked tremendous uncertainty for insurers. The Administration's steps to sabotage the ACA have also harmed the marketplace. President Trump issued an Executive Order on his first day in office instructing federal agencies not to enforce the ACA, cut the 2018 open enrollment period in half, and cancelled advertisements and outreach that helped people sign up for insurance. Most concerning, President Trump is threatening to stop paying cost-sharing reduction (CSR) subsidies that help keep premiums affordable for more than 156,000 Illinoisans.

Health insurance companies participating in the Illinois marketplace have cited this uncertainty as a direct cause for proposed 2018 premium increases. In its filing, Cigna--which is proposing an average 38 percent increase--wrote, "The federal government has not yet confirmed it will fund CSR subsidies in 2018. This rate filing assumes that CSRs are not funded and this assumption contributes to the average increase." Similarly, Blue Cross Blue Shield of Illinois--which proposed an average 16 percent increase across its plans--noted a factor in its proposed increases was, "the uncertainty regarding continued federal reimbursement for members' access to, eligibility for, and enrollment in CSR plans." In 2016, Illinois' largest marketplace insurer posted its best year under the ACA, and their 2017 profits indicate the marketplace was poised for another stable year. However, the Trump Administration's actions have jolted proposed 2018 premiums. More than 350,000 Illinoisans get coverage on the marketplace and should not suffer from this unnecessary and dangerous political gambit.

To address these concerning premium increases and provide greater information to Illinois consumers, we urge you to adopt measures that other state insurance commissioners have supported, including directing insurers to:

Re-file their individual market plans with two sets of proposed rates--one that accounts for continued CSR payment, and another without CSRs; and
Channel the increased cost due to CSR uncertainty into silver-tier marketplace plans to ensure that Illinois consumers receive premium tax credits that rise according to the cost of their health insurance--effectively shielding them from higher costs due to CSR uncertainty.
Further, we urge you to make public additional supporting and actuarial documentation that helps quantify the justification for proposed increases. We believe these commonsense measures are feasible and necessary to protect Illinois consumers.

Given the upcoming deadline for insurers to finalize their 2018 rates, we appreciate your expeditious efforts to protect Illinois families and consumers while ensuring robust competition and affordable premiums on the individual marketplace.

Sincerely,

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