State filing question

Has anyone encountered states that want every possible rate permutation to be filed publicly, but you filed a very flexible product with a lot of variation and that would be about a gajillion rates? And you gave them your rate manual but that was not good enough? (And I’m not even filing major medical. I can’t even imagine the variability in those plans.)

I work for one of those. I’m grateful to be the life actuary, so I’m spared from reviewing major medical. But I still do some health, and the state demands a lot more detail than most other states. To be fair, there are a lot of consumers watching our every move.

Our policy has 19 benefits, all of which can be in or out, with the exception of one or two. Just looking at the factors for one benefit there are at least 1600 possible rates. Some of the variability is the same across the entire contract, for example pre-x is a single factor. But still, that’s a lot of rates. I have filed the methodology and all the factors. I can’t imagine that they really want all the rates.

I have half a mind to generate all the rates. But I don’t think they really want that. I’m gonna see if I can get ahold of the analyst.

Back in the day I recall the Florida wanted every possible rate cell calculated and that was before electronic submissions. The rate filing we sent was this huge pile of papers too big for an envelope. They sent it in a box. It was crazy.


I cut my actuarial baby teeth on Florida. Either they have gotten easier to deal with or I have learned what they want. (knock wood)

Sometimes you just gotta give them a 30 page pdf with all the rates. If it’s easy to automate it isn’t too bad. Sure it’s dumb but not all of the things I have filled have made sense to file. Often political pressure influences some of the forms in health insurance so you just need to check a box.

Note: I haven’t filed in years now and never had to do this exact thing, but I did have to fill out a bunch of dumb stuff

Yep, I am probably just gonna have to do that. Not how I wanted to spend the 3 days before Thanksgiving but so be it.

The solution is to have fewer variables, so fewer rates are created.
Oh, and watch out for rounding issues.