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Stakeholders urge DFR to add prescription-drug breakout, plan-change details and plain-language appendix to consumer rate summaries
Summary
At the Sept. 24 advisory meeting, insurers, consumer advocates and actuaries debated how detailed a consumer-facing rate-review summary should be — urging a prescription-drug breakout, plan-change information, min/max ranges and a plain-language appendix to make filings usable for shoppers.
At the Sept. 24 Rate Review Consumer-Friendly Document advisory meeting, industry actuaries, consumer advocates and small-business participants debated how much detail the Division of Financial Regulation (DFR) should require in a consumer-facing summary of insurer rate filings.
Charlie Fisher, state director of OSPR, urged the committee to add more granular line items to the three-category rate-driver breakout the draft used and to pull prescription drugs out as a separate component so consumers can see a drug-specific contribution to requested rate changes. "It'd be great to have prescription drugs specifically pulled out as something that people can look at as separate from the rest of the trend," Fisher said.
Actuaries on the call, including David Leibert (actuary, Kaiser), cautioned against both an overly long fixed list of drivers and an incomplete breakout that leaves a large, unexplained remainder. Leibert recommended allowing insurers' actuaries and DFR reviewers to populate a well-populated list of drivers and, when necessary, include a clear "other" explanation for residual change. He and other actuaries also recommended including minimum and maximum impacts (in addition to the average) so consumers can see the range of experience across enrollees.
Rob (a small-business participant) pushed for plan-level clarity, saying averages are difficult to translate into an individual buyer’s experience: "If you've been on the same plan for five years and all of a sudden you have an 18% increase, you wanna know why and how much influence you have over any of it." Several participants suggested adding a short, plain-language appendix (prepared by DFR staff) with standardized definitions so line items are consistent and usable across filings.
The committee also discussed how to report which plans are "impacted" by a rate request. Participants suggested listing counts by metal tier and highlighting terminated or new plans rather than printing exhaustive plan lists that could be hundreds of lines for carriers with many products. The DFR said a condensed approach (e.g., "of 15 plans, 3 terminate and 2 are new") could be used and that staff would likely prepare a standard explanatory document outside the formal rule text.
The discussion touched on equity and fiscal-impact statements; DFR staff said they expect compliance costs to be minimal for carriers because much of the information already exists in filings, though producing visual maps could add modest administrative work. The committee closed with DFR keeping the public-comment period open and asking for written comments on rule text by Oct. 3.
Next procedural step: DFR requested written feedback by close of business Oct. 3 and said it hopes this will be the last advisory meeting before filing the rule.
