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July 30, 2015

Kevin Counihan
Chief Executive Officer, Health Insurance Marketplace
Director, Center for Consumer Information & Insurance Oversight
Department of Health & Human Services
200 Independence Avenue SW
Washington DC 20201
Dear Mr. Counihan,
Attached are comments from Consumers Council of Missouri on the
proposed health insurance rate increases the carriers have proposed for Missouri
for 2016 that exceed 10 percent. In our comments we ask that the department
find those increases unreasonable. Our comments include a statement applying
to all the increases that explains the reasons they are unreasonable, as well as
specific observations on the individual increases.
We also ask that you hold a hearing on Coventrys proposed increases. As
you noted in your letter of July 21, 2015, to state insurance commissioners, many
states have found the use of public hearings helpful in rate evaluation. Such
hearings could also be helpful to HHS in the five states in which it reviews rates.
While HHS clearly does not have the resources to hold a hearing on every
proposed increase subject to review, it may wish to consider holding a hearing
when a proposed increase meets at least one of three criteria: (1) the increase is at
least twice the 10 percent threshold that triggers HHSs review for
unreasonableness; (2) the carrier filing the increase has a substantial share of the
Exchange market; or (3) the carrier does not provide adequate support in its
filing for the increase. In Missouri, four of Coventrys five increases meet all
three of these criteria. We therefore ask that HHS hold a hearing on those
increases in connection with the departments evaluation of their reasonableness.
Finally, we recognize that HHSs making actuarial memorandums public
-- even redacted versions -- is a major step forward. However, HHS has said in
its rate review regulation that the entire memorandum should be made public.
Many states make the entire memorandum public when it is filed, and those
states have experienced no adverse effect on competition as a result of making it
public. Even in Missouri at least one carrier filed an unredacted memorandum
for 2016, and several did for 2015.
We are therefore asking HHS to make the entire actuarial memorandum
public in the future unless a carrier, after reasonable notice by HHS, sues to
enjoin it. That is a routine procedure followed by government agencies, and it is
the procedure HHS followed when it made the redacted actuarial memorandums

Consumers Council of Missouri, Page 2

Thank you for your consideration of these comments. We would be

happy to answer any questions you or your staff might have as you evaluate the
reasonableness of the proposed Missouri health insurance rate increases for 2016.

Joan Bray, Executive Director