After NORC obtained the rate filings by downloading them from websites or the other means described above, multiple challenges remained. Within the same state, and sometimes within the same carrier, rate filings differ greatly in format. Some were only a few pages long, while others exceeded 100 pages, with some actually thousands of pages long with the useful information hidden somewhere within. Longer documents display actuarial assumptions. A typical product submission will display different plans embedded with a product, each with its own premium level. Plans bundled together in a single filing usually offer the same benefits but have different levels of cost-sharing. Fortunately, more filings in later years were submitted using a consistent format, the System for Electronic Rate and Form Filing (SERFF). Use of this format is becoming increasingly common and will address many of the challenges of building a standardized database derived from heterogeneous source documents.20 All states accept filings submitted using the SERFF system. Table 4 provides a list of states requiring all filings to be submitted through SERFF.
Table 4: Requirements for Filing SERFF Forms, by State
|State||In Final Sample||Required to use SERFF Forms?||Year SERFF Requirement Began|
|District of Columbia||No||Yes||2007|
Note: Only states either in the final sample or required to use SERFF forms are listed. Source: State SERFF Mandates, http://www.serff.com/index_state_mandates.htm (life, accident, and health requirements only), accessed August 28, 2016.
As the study progressed, NovaRest obtained filings from sampled states and carriers. Filings came in the form of documents copied and converted into PDF by Perr & Knight, electronic filings downloaded from state websites, summary information on filings in a particular time period downloaded from state websites, and filings sent directly by a state insurance department at NovaRest’s request. Table 5 outlines the methods used to obtain filings for each of the states included in our sample.
NovaRest reviewed each of these rate filings and entered data from the filing, including information identifying the carrier, type of product, market, approval policies of the carrier’s state (file and use versus prior approval), target MLR, and other elements relevant to our research questions (see Appendix C for a complete list of data elements extracted from filings). Following this process, NORC staff continued to add to the database based on ongoing additions to filings from 2011. The findings presented in this version of the report are based on all filings entered into the database forwarded to ASPE on July 20th, 2012.
Table 5: Data Collection Methods Employed, by State
|State||Perr & Knight Obtained Physical Filings||NORC Team Direct Contact with Insurance Departments||Public Website with Summary Documents||Public Websites with Filings|
Note: Only states where filings were collected are listed.
20 SERFF aims to enable carriers to send and states to receive comments on filings including acceptances and rejections of rate and form filings. First developed by the NAIC in the 1990s, 27 states today mandate the use of SERFF in submitting health and life insurance filings to the state insurance department. SERFF provides a standardized format for filings that were historically characterized by a high degree of heterogeneity.