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Table of Contents
FEDERAL Rate Justification PART III Actuarial Memorandum & Actuarial Certification .................................. 4
Purpose.......................................................................................................................................................................................... 4
General Information ................................................................................................................................................................. 4
Company Identifying Information .................................................................................................................................. 4
Company Contact Information ........................................................................................................................................ 4
Proposed Rate Increase(s) ...................................................................................................................................................... 4
Reason For Rate Increase(s) .............................................................................................................................................. 4
Changes in Medical Service Costs .................................................................................................................................. 5
Changes in Benefits .............................................................................................................................................................. 5
Administrative Costs and Anticipated Profit............................................................................................................... 6
Experience Period Premium and Claims ........................................................................................................................... 6
Experience Period, Paid Through Date ......................................................................................................................... 6
Experience Period Premiums ........................................................................................................................................ 6
Experience Period Allowed and Incurred Claims ................................................................................................... 6
Benefit Categories ..................................................................................................................................................................... 7
Projection Factors ...................................................................................................................................................................... 7
Insured Population Morbidity Changes ....................................................................................................................... 7
Benefit Changes..................................................................................................................................................................... 7
Demographics Changes ..................................................................................................................................................... 7
Other Adjustments ............................................................................................................................................................... 8
Trend Factors (Cost, Utilization) ...................................................................................................................................... 8
Credibility Manual Rate Development............................................................................................................................... 8
Experience Data Used.......................................................................................................................................................... 8
Experience Credibility............................................................................................................................................................... 8
Insured Population Morbidity Changes ....................................................................................................................... 8
Benefit Changes..................................................................................................................................................................... 8
Demographics Changes ..................................................................................................................................................... 9
Other Adjustments ............................................................................................................................................................... 9
Trend Factors (Cost, Utilization) ...................................................................................................................................... 9
Paid To Allowed Ratio ........................................................................................................................................................... 10
Risk Adjustment and Reinsurance .................................................................................................................................... 10
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Actuarial
Purpose
The purpose of this actuarial memorandum is to provide information relevant to the
Part I Uniform Rate Review Template (URRT).
This document contains information that consists of confidential, proprietary trade
secrets under state and federal law. Under federal law, this information is exempt
from disclosure under Exemption 4 of the U.S. Freedom of Information Act, 5 U.S.C.
552, is a trade secret or confidential commercial or financial information as defined in
45 CFR 5.65, and protected from disclosure under 45 CFR 5.1 5.69, and 45 CFR
154.215 (i)(2). It may not be disclosed to any other person, including state or federal
regulatory agencies, unless UnitedHealthcare consents to the disclosure and the
recipient agrees in writing prior to receipt to maintain the confidential, proprietary
trade secret nature of the information herein.
General Information
Company Identifying Information
Company Legal Name: UnitedHealthcare of the Midwest, Inc.
State: Missouri
HIOS Issuer ID: 69117
Market: Small business, 2-50
Effective Date: 1/1/15
UnitedHealthcare is filing 2015 rates for new benefit plans that meet the coverage and
rating requirements of the Patient Protection and Affordable Care Act, as amended by
the Health Care and Education Reconciliation Act of 2010, collectively referred to as
the Affordable Care Act (ACA).
The primary drivers of the proposed rate increase(s) are the following:
Changes in benefits
Increased Utilization The number of office visits and other services continues to
grow. In addition, total health care spending will vary by the intensity of care and/or
use of different types of health services. Patients who are sicker generally have a
higher intensity of health care utilization. The price of care can be affected by the use
of expensive procedures such as surgery vs. simply monitoring or providing
medications.
Higher Costs from Deductible Leveraging Health care costs continue to rise
every year, while deductibles and copayments remain the same. As a result, a greater
percentage of health care costs need to be covered by health insurance premiums
each year.
Cost shifting from the public to the private sector Reimbursements from the
Center for Medicare and Medicaid Services (CMS) to hospitals are no longer covering
all of the cost of care. The cost difference is being shifted to private health plans.
Additionally, Medicare and Medicaid rates to hospitals are expected to decline due to
the impact of the Patient Protection and Affordable Care Act on Medicare and the
effect of the recession on Medicaid. A rate increase paid by Medicaid to hospitals is
often below the actual cost increase hospitals will experience.
Changes in Benefits
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Coverage Mandates Benefits are being enhanced to the meet Essential Health
Benefits (EHBs) and other ACA requirements such as the introduction of pediatric
dental and vision benefits. Plans will no longer include internal dollar limits on EHBs,
and all customer copays, including prescription drug copays, will count towards
satisfying the overall plan out-of-pocket maximum.
There were no allowed or incurred claims in 2013. The template would not allow an
entry of $0; therefore, $1 was entered instead.
Benefit Categories
Claims were assigned to benefit categories by our claim department using standard
industry definitions of services.
Prescription Drug: Includes drugs dispensed by a pharmacy, not dispensed by facility (i.e.
via inpatient, outpatient), and not physician administered drugs. This amount is net of
rebates received from drug manufacturers.
Projection Factors
Insured Population Morbidity Changes
Since UnitedHealthcare of the Midwest, Inc. has no recent experience, this information
was not included in the experience section of Section II, Worksheet 1. Information on
the adjustments made in developing the credibility manual are included in the
Credibility Manual Rate Development section of this memorandum.
Benefit Changes
Since UnitedHealthcare of the Midwest, Inc. has no recent experience, this information
was not included in the experience section of Section II, Worksheet 1. Information on
the adjustments made in developing the credibility manual are included in the
Credibility Manual Rate Development section of this memorandum.
Demographics Changes
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Since UnitedHealthcare of the Midwest, Inc. has no recent experience, this information
was not included in the experience section of Section II, Worksheet 1. Information on
the adjustments made in developing the credibility manual are included in the
Credibility Manual Rate Development section of this memorandum.
Other Adjustments
Since UnitedHealthcare of the Midwest, Inc. has no recent experience, this information
was not included in the experience section of Section II, Worksheet 1. Information on
the adjustments made in developing the credibility manual are included in the
Credibility Manual Rate Development section of this memorandum.
Experience Credibility
UnitedHealthcare Insurance Companys experience includes 520,238 member months.
We generally assign full credibility at 20,000 member years, or the equivalent 240,000
member months. Therefore, UnitedHealthcare Insurance Companys experience is
considered fully-credible.
Anti-selection from disruption in the historical renewal pattern due to ACR (Adjusted
Community Rating)
Benefit Changes
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Claims are expected to increase due to additional benefits required by the essential
health benefit package. The estimate of the cost of added essential health benefits
was developed using UnitedHealthcare national experience and was included in the
development of the credibility manual. The primary drivers of this increase are the
following:
Demographics Changes
Demographic changes, including aging of the population and the premium cap on the
number of members in a given family, were included in the development of the
credibility manual rates. The HHS proposed age factors are used in rating.
Other Adjustments
Additional adjustments were made to reflect network differences between
UnitedHealthcare Insurance Company and United Healthcare of the Midwest, Inc.
These adjustments were included in the development of the credibility manual.
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Each projected monthly index rate is adjusted for the following factors in order to arrive at a
premium rate:
Expected aggregated payments and charges under the risk adjustment and reinsurance
programs
Actuarial value and cost-sharing structure of the plan
The plans provider network, delivery system characteristics, and utilization management
practices
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Calibration
Member weighted average age factor and geographic factor have been developed to
calibrate the Plan Adjusted Index Rate.
Age Curve Calibration is calculated as member weighted average age rating factors (based on
ACR compliant national standard age curve) in experience period. The factor is calculated to
be: 1.41. Based on the Standard Age Curve, the nearest age is Age 44.
Geographic Factor Calibration is calculated as member weighted average rating area factors
(based ACR compliant rating area setting) in experience period. The factor is calculated to be:
1.01
UnitedHealthcare of the Midwest, Inc. has no recent small business experience. Therefore the
average age and average geographic factors are based on data from the UnitedHealthcare
Insurance Company experience.
Tobacco usage is not a rating factor been adopted by UnitedHealthcare. So, the tobacco
calibration is not applicable.
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AV Metal Values
All AV Metal Values were based on the AV Calculator. Some adjustments were made
to plan designs in order to appropriately model the designs in the AV Calculator.
When possible, data from the AV Calculator was used to make the adjustments. If the
necessary data from the AV Calculator was not available, adjustments were developed
based on UnitedHealthcares historical experience and proprietary pricing model.
These adjustments include the following:
Specialty Rx copays: All of the filed plan designs include multiple copay tiers for specialty
Rx. A weighted average of the specialty Rx copays was used in the AV Calculator, based on
UnitedHealthcares historical experience and proprietary pricing model.
99.9% Coinsurance: Some plan designs had a lower AV when 100% coinsurance was
entered into the AV Calculator, as compared to identical plan designs with 80% or 90%
coinsurance. When assuming 99.9% coinsurance produced more reasonable results, 99.9%
coinsurance was assumed instead of 100%.
OP Surgery Facility Copays: Some plan designs include a per-occurrence copay which
applies to outpatient surgery facility claims before applying the deductible and
coinsurance benefits. These copays were converted to equivalent effective coinsurance
rates based on UnitedHealthcares historical experience and proprietary pricing model. The
tiered network functionality in the AV Calculator was used to run the plans through the
model in two ways: once with the effective outpatient surgery facility coinsurance rate and
once with the coinsurance rate for other OP service types. The tiered network weights
were based on UnitedHealthcares historical experience and proprietary pricing model.
IP Facility Copay: Some plan designs include a per-occurrence copay which applies to
inpatient facility claims before applying the deductible and coinsurance benefits. These
copays were converted to equivalent effective coinsurance rates based on the continuance
tables included in the AV Calculator. The tiered network functionality in the AV Calculator
was used to run the plans through the model in two ways: once with the effective facility
coinsurance rate and once with the professional coinsurance rate. The tiered network
weights were based on UnitedHealthcares historical experience and proprietary pricing
model.
AV Pricing Values
The AV Pricing Value represents the cumulative effect of adjustments made to move from the
market adjusted index rate to the plan adjusted index rate. It is the total of the adjustments
listed in the plan adjusted index rate section: actuarial value and cost sharing, provider
network, delivery system, and utilization management, and distribution and administrative
costs.
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Membership Projections
February 2013 membership on UnitedHealthcare Insurance Company plans was mapped
to similar plans which will be offered in 2014; some of those groups were assumed to
migrate to plans on the UnitedHealthcare of the Midwest, Inc. license in 2014. Groups
were assumed to migrate to the new plans upon renewal. No persistency or new business
sales assumptions were included in the projected membership.
Terminated Products
This section is not applicable since there are no current products.
Plan Type
All plans fall under the HMO plan type.
Warning Alerts
There are two warning alerts on Worksheet 1:
Experience period member months are equal to zero: There has not been any small
business membership on this license since 2010. As such, no experience has been entered
in Section I, Worksheet 1.
The index rate for the projection period is greater than the projected allowed
experience claims PMPM: This difference is explained by the index rate development in
the Index Rate section of this document.
There are six warning alerts due to differences between the plan level projections in
Worksheet 2 and the total projected amounts found on Worksheet 1.
Plan Adjusted Index Rate: The PAIR in Worksheet 2 is higher than the single risk
pool premium calculated in Cell V43 of Worksheet 1 because the premium in
Worksheet 1 represents the projection period 1/1/15 12/31/15, whereas the PAIR in
Worksheet 2 reflects trend adjustments by accounting for rate effective dates
throughout the projection period.
Total Premium: The Total premium in Worksheet 2 is higher than the premium
calculated in Cell X43 of Worksheet 1 because the premium in Worksheet 1
represents the projection period 1/1/15 12/31/15, whereas the premium in
Worksheet 2 reflects trend adjustments by accounting for rate effective dates
throughout the projection period.
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Total Allowed Claims: The Total allowed claims in Worksheet 2 is higher than the
allowed claims calculated in Cell X32 of Worksheet 1 because the claims in
Worksheet 1 represents the projection period 1/1/15 12/31/15, whereas the claims
in Worksheet 2 reflects trend adjustments by accounting for rate effective dates
throughout the projection period. This is true for the PMPM calculation and the total
claim calculation.
Total Incurred Claims, payable with issuer funds: The incurred claims in
Worksheet 2 is higher than the incurred claims calculated in Cell X38 of Worksheet 1
because the claims in Worksheet 1 represents the projection period 1/1/15
12/31/15, whereas the claims in Worksheet 2 reflects trend adjustments by
accounting for rate effective dates throughout the projection period. This is true for
the PMPM calculation and the total claim calculation.
Reliance
I have relied on UnitedHealthcares Finance Department to provide the Non-Benefit
Expenses and Risk Margin information, including administrative expenses, profit and risk
margin, taxes and fees, and the projected loss ratio under the federally prescribed MLR
methodology.
Actuarial Certification
I, Paul Knepp, am a Fellow of the Society of Actuaries and a Member of the American
Academy of Actuaries.
I satisfy the 2013 continuing professional development
requirements of the Academy and therefore am qualified to issue this 2014 statement of
actuarial opinion. I have reviewed applicable ASOPs during the preparation of this rate
filing. I have worked on the pricing of group medical expense insurance for over 10 years.
In compliance with all applicable State and Federal Statutes and Regulations (45 CFR
156.80(d)(1)),
I certify that the index rate and only the allowable modifiers as described in 45 CFR
156.80(d)(1) and 45 CFR 156.80(d)(2) were used to generate plan level rates.
I certify that the percent of total premium that represents EHBs included in Worksheet
2, Sections III and IV was calculated in accordance with actuarial standards of practice.
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I certify that the AV Calculator was used to determine the AV Metal Values shown in
Worksheet 2 of the Part I Unified Rate Review Template. For plans designs that did
not fit into the AV Calculator, included in this Part III Actuarial Memorandum is a
description of the methodology and numerical values used to develop the AV metal
values, and a certification as required by 45 CFR Part 156, 156.135.
I qualify my opinion to state that the Part I Unified Rate Review Template does not
demonstrate the process used by UnitedHealthcare to develop the rates. Rather, it
represents information required by Federal regulation to be provided in support of
the review of rate increases, for certification of qualified health plans for federally
facilitated exchanges, and for certification that the index rate is developed in
accordance with Federal regulation and used consistently and only adjusted by the
allowable modifiers.
Sincerely,
PaulKnepp,FSA,MAAA
Actuary,UnitedHealthcare
1300RiverDrive,Suite200
Moline,IL61265
3097576399
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69117
95426MO002
Applicable HIOS Plan IDs (Standard Component): See the AV Metal Values section of
Reasons the plan design is unique (benefits that are not compatible with the parameters of
the AV calculator and the materiality of those benefits):
See the AV Metal Values section of the Part III Actuarial Memorandum
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Confirmation that only in-network cost sharing, including multitier networks, was
considered:
Only in-network cost sharing was considered
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If the method described in 156.135(b)(2) was used, a description of how the benefits
were modified to fit the parameters of the AV calculator:
See the AV Metal Values section of the Part III Actuarial Memorandum
If the method described in 156.135(b)(3) was used, a description of the data and
method used to develop the adjustments:
See the AV Metal Values section of the Part III Actuarial Memorandum
Certification Language:
The development of the actuarial value is based on one of the acceptable alternative methods
outlined in 156.135(b)(2) or 156.135(b)(3) for those benefits that deviate substantially from
the parameters of the AV Calculator and have a material impact on the AV
The analysis was
(i) conducted by a member of the American Academy of Actuaries;
(ii) performed in accordance with generally accepted actuarial principles and methodologies;
Actuary signature:
Actuary Printed Name:
Date:
Paul J. Knepp
7/1/14
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