HCA’s Rate Review Role

For general information about the rate review process, see our Health Insurance Rate Reviews page.

Why does the Office of the Health Care Advocate look at rate filings?

The Office of the Health Care Advocate (HCA) reviews rate filings to see if the premium price change will be bad for Vermonters. We compare the proposed premium price to the amount the insurer is likely to spend on medical bills for Vermonters. We also look at the proposed price change compared to what Vermonters earn and Vermont’s cost of living. Often, premium prices are increasing faster than Vermonters’ wages and other costs like rent and groceries. We look at whether the proposed premium price will make it harder for Vermonters to access care, will affect quality of care, or will unfairly hurt certain groups of Vermonters.

If we think the premium price change will hurt Vermonters, we explain this to the Green Mountain Care Board and ask the board to lower or reject the price increase.

What is the rate filing review process?

The HCA begins by gathering information on the rate filing. We carefully examine the information to identify errors or problems. If the filing is very complicated, we often hire an actuary (an expert in mathematics and statistics) to review the rate filing.

We look at whether the rate filing meets Vermont’s legal criteria.

Is it affordable?
Does it promote quality care?
Does it promote access to health care?
Does it protect the insurer’s ability to pay claims?
Is it unjust, unfair, inequitable, misleading or contrary to law?
Is it excessive, inadequate or unfairly discriminatory?

If the rate filing fails any of these legal factors we explain why it fails to the Green Mountain Care Board.

In many cases, we submit questions to the board that we would like the insurance company to answer. The board decides whether or not to send our questions to the insurer.

Finally, if our team finds that the price change is not affordable or otherwise fails to meet Vermont’s legal standards, we participate in the rate review hearing and/or submit written arguments to the board. In many cases, we argue that the proposed rate should be lowered and ask the Green Mountain Care Board to either reduce or reject the price increase. If the board rules against us, we can choose to appeal the decision to the Vermont Supreme Court.