FEEDBACK

and Human Services

Dear Secretary Sebelius:

The spiraling increase of cost of group health insurance is a concern to us all. I am writing this letter to state that I sincerely believe a health insurance agency (agent) is an extremely valuable asset in controlling the cost of health insurance premiums at the time of renewal. As you are aware, the insurance agency works for the employer and not the carrier. The agent’s perseverance, almost always finds a way to negotiate a lower rate than the one quoted by the carrier at renewal. A case in point: with every renewal we received for our clients that employ over 50, for calendar year 2011, we were able to secure a better rate than the one presented by the carrier. Rate reduction is accomplished by securing competitive bids and/or carefully analyzing the claims experience of the previous year and discussing those nuances with the carrier.

As an example, our agency was an advocate for our largest client in controlling the amount of renewal increase received from the carrier for a 10/01/2010 renewal date. (We are declining to mention by name either the client or the carrier in this case.) In doing our independent analysis of the premiums and claims, for the previous year, an increase in the premiums was necessary. We believe, for this client, the increase should have been approximately 15%. The first renewal rate action from the carrier, however was a 23.1% increase. In some cases, this raised the price of individual health insurance from $382.80 to $472.33, and the price of family health insurance from $1,114.00 to $1,372.33.

Over a period of 60 days, through competitive pricing and a discussion with the carrier, we received a total of five renewal quotes before an agreement was reached on a 16.6% increase. The first, as stated, was 23.1%; the next was 21.2%; the next 20.6%; the next 18.6% and finally 16.6%. The last rate resulted in price increases as little as $63.54 for individuals and $184.92 for families.

Moreover, the medical loss ratios for the first six months of our client’s renewal period (61.0%, 82.4%, 63.9%, 115.5%, 67.8% and 82.3%, for an average of 78.9%) was is in line with the final increase, showing the value of our advocacy for our client. Granted, this is an extreme case to get five rate reductions. However, as stated previously, with every group of over 50 employees, after negotiation with the carrier or carriers, the original renewal rate was negotiated to a lower rate. Further, with two of our groups, having fewer than 50 employees, the carrier typically does not negotiate their renewal rate; we were able to secure a lower renewal because we were able to prove to the carrier the demographics of the group had changed.

Cases like this one are not atypical. They happen daily throughout the country. Agents and their staff represent clients in finding the most competitive rates available. This brings me to my first request. Please consider allowing the agency’s commission to be excluded from the 15% or 20% the carrier has for their overhead. If the insurance agency’s commission (5%) is to be included in the medical loss ratio (80% or 85%) the carrier must spend on claims; this will have the effect of neutralizing the strongest advocate the employer has in the fight against sometimes exorbitant annual rate increases. The carrier, potentially, will reduce our commission dramatically, thereby eliminating staff that works every day helping the insurer negotiate the bureaucracy of the carrier and solving a multitude of problems. It is my understanding that representatives like Mike Rogers of Michigan and John Barrow of Georgia are preparing to introduce a bipartisan MLR commission bill in the House. An MLR exclusion commission bill is “an adjustment that never should have been drafted this way in the first place,” according to Jessica Waltman, a NAHU vice president. It is my understanding that the state of Maine has adopted an MLR exemption for the state’s producers. There is tremendous value to the employer and employees to have an agency as an advocate. I believe the examples that we have provided herein will show that value. If it is convenient for you, please share this letter with Senator Rockefeller and others that may be interested in discussing this further.

In Oklahoma, in the recent past (2002), Blue Cross Blue Shield of Oklahoma allowed two separate association plans to be formed; one for community banks and the other for manufacturers. These association plans proved to be successful. There were approximately 70 banks and over 200 manufacturers on these two separate plans. The reason for the success was twofold. One, each bank or manufacturer became a member of their association health plan at different rates based on their demographics and location. Second, the claims were pooled in order to spread the risk. In 2008, Blue Cross decided association plans were illegal in the state of Oklahoma. Therefore, the two groups no longer had their claims pooled. The result of this decision left many small banks and manufacturers with dramatic renewal increases that they would not have had if they were in an association plan that pooled claims. Pooling the claims and spreading the risk was and would be good for all. There is a possibility new legislation in Oklahoma ma be passed this month, which would correct our state law and allow association plans to pool claims.

My second request is that you kindly consider adopting regulations, through PPACA, that would allow association plans to pool their claims. Under today’s PPACA legislation for 2011, many small banks and manufacturers would now be part of a large group and 85% of their premiums would be spent on claims. As you are aware, under the PPACA legislation, only 80% of the premiums are mandated to be spent on claims for groups with less than 50 employees. Mandating 85% of the premiums will help the smaller entities that are members of an association pan. Also, it is our understanding that the administrative cost,by the carrier, would be reduced. Therefore, members of the association would have a built-in savings from the start. It is certainly a fact that claims will drive the renewal rtes for the coming year. It is also a fact that spreading the risks over thousands of lives will stop the dramatic spike in rates for a smaller company that has one serious illness.

I am aware that controlling the escalating cost of health care is extremely important to you and your office. I believe that the two requests that I have made above will greatly assist you in that effort. Further, may I refer you to the March 14th article in Forbes magazine written by David Whelan. Whelan’s interview of Clayton Christensen, Harvard’s innovative professor, contains recommendations on controlling the costs of health care. His recommendations deal with reducing the cost of health care from the provider to the consumer.

I appreciate the time it has taken to read this letter. I wish you the very best.

Richard S. Lillard, CEO
Richard S. Lillard Company
Miami, OK

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