Going From “The Surprise Me State” to “The Show Me State”: The Missouri Health Insurance Rate Transparency Act

In July, the Missouri Health Insurance Rate Transparency Act (SB 865) was signed into law, making MIssouri the most recent state to establish (as of its 2018 implementation) a review process for health insurance rates advance filed with the MIssouri Department of Insurance. Yes, we have gone from being the "Surprise Me State" to being the "Show Me State." Only Oklahoma, Texas, and Wyoming continue on without health insurance rate review on the state level as Alabama has also only recently come into the fold. 

Missouri's rate review focuses on whether or not the proposed increases are reasonable. This will require significant data testing and analysis before producing a determination of reasonableness or unreasonableness. Then, the state will have the authority to ask the insurers to revise their submitted rates. Note that there will be no authority for MIssouri to force revision of the filed rates,  just the leverage of public scrutiny.  In this, Missouri's rate review is much like that of California's and a number of other states: the power of sunshine as a disinfectant is the true mechanism for rate review.

Let the rate filing and rate reviewing begin, complete with opportunities for public notice and comment. Those health insurers who sell into the Missouri market will need to change gears here as they were long accustomed to operation in a state that not only lacked adequate rate review, it required absolutely no advance filing of health insurance rates at all.  Time will tell if Missouri is prepared to be proactive on health insurance rate increases and not only, at best, reactive. 



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