Effects of Implementing State Insurance Market Reform, 2011-2012. Limitations


While this report presents data from the current study alongside data from the Trends study, comparisons across the years should be made with caution. The Trends study included a different sample of states, employed different methods of data collection, and presented an incomplete picture of insurance filings in 2011 because data collection ended in the fall of that year.

This report can present descriptive analysis of the trends in rate increases in periods before and after ACA rate review took effect, but there is no way of knowing what would happen absent the ACA, as its provisions apply to all states. NORC did not conduct multivariate analyses to test the impact of factors unrelated to the ACA that may also have affected premium increases. It is possible that the “Great Recession” and a sudden decline in claims expenses in 2009 and 2010 contributed greatly to the slowing of premium increases. We note, however, that 2010 was a year of the highest premium increases in the individual market based on our 2008-2011 analysis in the Trends study.

Second, in both the individual and small group markets, we cannot explain why the number of fillings sometimes fluctuates dramatically from year to year for a given state.

Third, for some data fields in some filings, data were either missing or seemingly implausible. For example, some filings were missing either requested premium increases or approved rate increases; in these cases, we were unable to assess whether state regulators modified the rate originally proposed by the carrier, and so these observations were omitted from analysis of that question. In other instances, available data seemed implausible. For example, in some cases, the total reported enrollment in multiple filings from the same year by a single carrier summed to a figure much greater than that carrier’s entire enrollment listed in the NAIC April Supplemental Report, suggesting that some enrollees may have been double-counted in the filings. Where enrollment data is missing or implausible, the weighting methodology employs the data from NAIC on state insurer enrollment in the individual and small group markets to cap the maximum possible weight such filings can receive. From sensitivity testing conducted for the Trends study which had similar data, we believe that measures of central tendency in this report are robust to the particulars of the weighting method used.

Finally, it is important to note that state procedures for posting filings in their public portal and their process for reviewing filings vary, even among states that have the same regulatory authority (file and use or prior approval). In some states a new filing is filed under a separate tracking number in response to a regulator’s rejection to an initial proposed rate and in other states filings capture the revised rate increase in a single filing. Additionally, although use of the SERFF portal and the SERFF file template did improve the consistency of the information presented in filings, in some cases sections of the template were left blank or could only be found in the correspondence attached to the filing. As such, while the completeness of the filing documentation submitted by carriers has improved since the beginning of the Trends study, the data presented in this report is subject to the limitations of its sources.

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