oxford health insurance, inc. small group 2020 public comments€¦ · make more insurance more...

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Oxford Health Insurance, Inc. Small Group 2020 Public Comments We are a small business that just received notification that United Health Care / Oxford is requesting a 18.6% premium increase. Our rates were already increased last year. They claim increasing medical costs necessitate the increase while upper management bonuses and compensation are certainly not affected. It seems they want to charge more and pay out less to the detriment of most people. We started with this group plan on august of 2006 and every single year there's a big increase. Eventually we won't be able to afford it and this is not fair to us as we don't have claims other than regular doctors apptmt....everything goes up but the salaries. I understand increases, but every single year is outrageous We will not be able to continue to offer health care to our employees if this increase in premium is approved. It is absurd as well as not affordable! The premium increase of 18.1% is radically high and does not reflect the CPI change and should be declined. Please explain why a horrible rate increase is proposed for 2020 please advise how am I supposed to pay for it? The entire Medicaid/health system is flawed, unbalanced, needs to be properly managed. Thank you. We will not be able to pay a 13.7% increase in premium. Increases have been out of hand for the past few years, but a 13.7% increase cannot be approved. I would like to state for the record that a 15.6% increase is exorbitant. Health care is barely affordable as it is, and 15.6% of our monthly premium is over $95 more per month. This affects both employees and employers. If other business raised their prices at that rate they would lose most of their customers, but with health care the consumer has no choice. An increase like this will make health care unaffordable for many. I hope the DFS will consider the well being of its citizens. The 17.9 % increase Oxford/United Healthcare is requesting is beyond outrageous. The company has requested and received double digit increases every year since the plan was founded, and our premium costs have doubled in recent years. In 2018, United Healthcare reported earnings UP by 12 percent last year. Despite claiming rising costs, their profits are growing higher. My basic plan for me and my teenage son cost me nearly $20,000 AFTER TAXES. Please stop the price gouging by these greedy insurance companies! We will not be able to afford insurance if this continues.

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Page 1: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

We are a small business that just received notification that United Health Care / Oxford is requesting a 18.6% premium increase. Our rates were already increased last year. They claim increasing medical costs necessitate the increase while upper management bonuses and compensation are certainly not affected. It seems they want to charge more and pay out less to the detriment of most people.

We started with this group plan on august of 2006 and every single year there's a big increase. Eventually we won't be able to afford it and this is not fair to us as we don't have claims other than regular doctors apptmt....everything goes up but the salaries. I understand increases, but every single year is outrageous

We will not be able to continue to offer health care to our employees if this increase in premium is approved. It is absurd as well as not affordable!

The premium increase of 18.1% is radically high and does not reflect the CPI change and should be declined.

Please explain why a horrible rate increase is proposed for 2020 please advise how am I supposed to pay for it? The entire Medicaid/health system is flawed, unbalanced, needs to be properly managed. Thank you.

We will not be able to pay a 13.7% increase in premium. Increases have been out of hand for the past few years, but a 13.7% increase cannot be approved.

I would like to state for the record that a 15.6% increase is exorbitant. Health care is barely affordable as it is, and 15.6% of our monthly premium is over $95 more per month. This affects both employees and employers. If other business raised their prices at that rate they would lose most of their customers, but with health care the consumer has no choice. An increase like this will make health care unaffordable for many. I hope the DFS will consider the well being of its citizens.

The 17.9 % increase Oxford/United Healthcare is requesting is beyond outrageous. The company has requested and received double digit increases every year since the plan was founded, and our premium costs have doubled in recent years. In 2018, United Healthcare reported earnings UP by 12 percent last year. Despite claiming rising costs, their profits are growing higher. My basic plan for me and my teenage son cost me nearly $20,000 AFTER TAXES. Please stop the price gouging by these greedy insurance companies! We will not be able to afford insurance if this continues.

Page 2: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

The increase is too high. The insurance costs so much already it is unfair to impose a drastic increase.

The proposed rate change by Oxford is going to make insurance for my small family of 3 completely unaffordable. My husband has already opted out of insurance to save us money, and we have a baby on the way who will need insurance. Right now, the rate for the baby is $380; however, with the proposed rate change the new rate would be over $50 more per month, putting the rate for a small family of three over $2300.00. We will not be able afford to keep the baby on this insurance plan. 14.3% is an outrageous increase. I am a physical therapist working for a small out patient clinic in NYC. I don't even bring home $2300 in one paycheck. Please do not approve this rate increase it will end up forcing small families and business owners to move out of state.

Hello, I write to file an objection on the proposed premium rate increase of 17.6%, recently filed by Oxford Health Insurance, Inc. This proposed rate increase will be a major hardship for our small business. I believe that my carrier’s profits, administration, and executive compensations costs are too great and urge you to require it to invest more premium dollars into its customer’s health expenses. I strongly support the Department of Financial Services’ efforts to make more insurance more affordable and information about rate increases more accessible. Thank you for your attention to this matter. If you need more information about our situation, please feel free to contact me at

Thank you.

Hello, I write to file an objection on the proposed premium rate increase of 15.3%, recently filed by Oxford Health Insurance, Inc. This proposed rate increase will be a major hardship for our small business. I believe that my carrier’s profits, administration, and executive compensations costs are too great and urge you to require it to invest more premium dollars into its customer’s health expenses. I strongly support the Department of Financial Services’ efforts to make more insurance more affordable and information about rate increases more accessible. Thank you for your attention to this matter. If you need more information about our situation, please feel free to contact me at

Thank you.

Hello, I write to file an objection on the proposed premium rate increase of 13.0%, recently filed by Oxford Health Insurance, Inc. This proposed rate increase will be a major hardship for our small business. I believe that my carrier’s profits, administration, and executive compensations costs are too great and urge you to require it to invest more premium dollars into its customer’s health expenses. I strongly support the Department of Financial Services’ efforts to make more insurance more affordable and information about rate increases more accessible. Thank you for your attention to this matter. If you need more information about our situation, please feel free to contact me at

Thank you.

Page 3: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

This is an outrages request. The percentage increase of 14.8% cannot simply be the result of increases in the cost of care. UnitedHealthcare states that the reduction of the 2020 risk adjustment increases its requested rates by 0.3%. How does this justify an increase in premiums 49 times as large? While costs increase, as does usage, I understand that profits may suffer. However, a changing landscape is part of the nature of business. An insurance company that claims to aim to keep people healthy shouldn't have the right to pillage because it wants to increase, not simply maintain profits. Deny this request.

Over the last 5+ year, United Health Care has consistently raised prices and reduced coverages. Meanwhile its share price has risen over 350% and their CEO is paid $18m per year. They are claiming that they need to raise premiums again in 2020 by 13.2%. These premium increases are unconscionable - they continue to bankrupt hard-working American families, while their shareholders and management reap all the rewards. Let's make America fair again!

Our group plan has just renewed at substantial premium increase. 9 days into the increase, I receive a notice that Oxford has requested a 15% increase for next year. I pay exorbitant rates for myself and my staff, my premiums continue to rise and my coverage continues to get reduced. I VEHEMENTLY oppose this request for yet another rate increase and respectfully urge you to do everything in your power to DENY it. Many thanks!

TO WHOM IT MAY CONCERN, REQUESTING MORE DETAILS AS TO WHY INSURANCE IS GOING UP 17.4%. ALSO REQUESTING AN APPEAL FOR THE RAISE IN PERCENTAGE. THANK YOU. SINCERELY,

I cannot have an increase in my health insurance due to many many facts... 1. For a single individual, my plan is approx.$890 a month. That is JUST FOR ME!!!! 2. Every time I walk into a doctors office I pay a $60 copay 3. This insurance company denies many of the claims, and I pay an astronomical amount of money to all my doctors. I am on SEVERAL payment plans. 4. I needed a (NOBODY wants to go through this) and my Insurance company wouldn't pay in full. THIS IS NOT cosmetic surgery, I was petrified 5. the Insurance company wouldn't pay for an MRI, so instead they said I needed to have physical therapy at $60 a visit, after I did that they approved the MRI but didn't pay for it in full. I never should have had the physical therapy. I can go on and on but my main point is that I cannot afford anymore monthly payments, because I am paying a HUGE deductible, and non covered fees. I work very hard, and full time but I am not offered payed health insurance. I am not in a union where I will get health Insurance for life. Stop paying for uninsured illegals, and maybe you can lower your fees. PLEASE PLEASE do not increase my monthly bill. PLEASE

Page 4: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

Hello, I just received notice that our United Healthcare Oxford Insurance plan is requesting a 13.4% increase in premiums from your department. This increase is excessive and would be a great strain financially on all employees. I would urge the department to reject the proposed rate change. Thanks very much,

DO NOT let them raise the rates.

Medical prices are too high as it is. A 14% increase would make my medical insurance unaffordable. Please do not approve this increase.

I was extremely distressed to learn that my health insurance provider, Oxford Health Insurance, Inc., has filed a request with DFS for a staggering 17.4% increase. Despite annual increases in my premiums, my overall coverage has been reduced and my deductible has increased year over year. I am strongly opposed to the proposed increase and feel it is not fair and certainly not warranted.

Hi, I noticed that Oxford is requesting to raise my premium rate next year, I see why they do this, but I sincerely think that is not necessary given that I am a pretty healthy person in general, and the only reason for rising medical expense this year is that I had a earlier this year, and I had to be admitted in hospital for several days, and that cost a lot of money. But the bottom line is I got treated because of accident, NOT illness. And I don't think it would affect my next year since there is really no pre-existing conditions to be treated. Thanks!

To It May Concern: This request to increase premium by 15.7% has no merit. Especially in the economy with no inflation over the last 11 years. Under such circumstances it is reasonable to expect material and ongoing declines in premiums. Instead of taking an easy and path of unjustifiable price increases, healthcare as well as insurance providers should focus on reducing their costs. Thank you,

Page 5: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

Dear Sir/Madam, I have just received a letter from United Healthcare stating that they are applying for increase in health insurance group premiums for 2020 with the exact percentage of 13.2% increase. As a New York State tax payer, We find it to be unacceptable. United Healthcare is a Minnesota based for profit company. Their objective is to make money no matter what their clients need and expect from them. United Healthcare made 17 Billion Dollars net profit in 2018. Source: https://www.businesswire.com/news/home/20190115005285/en/UnitedHealth-Group-Reports-2018-Results-Highlighted-Continued United Healthcare made 3.5 Billion Dollars net profit in the first 3 months of 2019. Source: https://www.beckershospitalreview.com/payer-issues/unitedhealth-posts-3-5b-profit-in-q1.html This is a company that makes billions of dollars of net profit by charging high premiums to small businesses of New York in a healthcare insurance market with limited to no competition. Since When small businesses in New York can increase their products'/services' prices by 13.2%? It is just not possible in this competitive marketplace. While New York based small businesses can't increase their revenue (not to mention no profit), How come United Healthcare has the luxury of increasing prices by 13.2%? Do they have to make 17 billion dollars of net profit every single year? Besides, they just increased premiums this year!? The annual inflation in U.S. is 2%. That is it. Now let's compare 2% to 13.2%. As a matter of fact; With 17 billion dollars in their pockets, they are supposed to reduce their prices for 2020. Please disapprove their request to increase premiums. They have no legitimate basis to increase prices. What they are asking is excessive. We, as small businesses in New York, are struggling to compete against foreign competition while creating jobs and paying our taxes. What United Healthcare demonstrates is called old-fashion CORPORATE GREED. Thank you, Sincerely yours,

I received a notice of a proposed increase of 16.6%. This is an unsustainable increase for me and most middle class/lower class individuals. I now pay an outrageous premium for one person... over $1200 mo. I only bring home pay of ? I don't get a 16.6% raise every year!! If ANY!! How can I keep affording this? But yet, I'm held hostage to this absurd cost, because I would have to go bankrupt or worse if I have no insurance and needed major healthcare.These insurance costs contribute to more and more people having no insurance or qualifying for medicare and thereby draining our economy even more. Stop this madness!! Our nation needs to reel this costs in....in all ways.

OHI's proposed 17.8% increase is egregious, and if paralleled with financial restrictions, is borderline usurious. Since OHI's communication to the insured individual waivers between nary and none-existent, the entirety of the filing is not made available to the end consumer. Consequently, OHI's view of projected claims is unsubstantiated within the half-letter notice I/everyone was mailed. To wit, the only substantiated cost increase projection properly articulated is: increase[s] our...rates by 0.3%. Approve a 0.3% increase. OHI is synthetically projecting higher than an expected costs because their real costs projects are so low, and out of line with recent past cash grabs. Any mention of their profit projections year over year? Yeah, not in my letter either.

received a mail of letter to guide me here.

Page 6: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

For real...insurance going to go up 17.9%????????? The insurance rate has been going up way faster than people's wage...how is that even acceptable.

I recently received Oxford's notice of proposed premium rate change (W17282, CSP20, EPO Gold, 85629NY0010240 refers). An increase in premium of 17.6% is unreasonable as it is well beyond the annual increase in living expenses and the current rate of inflation.

I wanted to understand more about how this will impact what I pay.

Oxford Health Insurance has filed for 13.2 % increase beginning 2020. I am against the increase. because this will be the third premium increase for the third consecutive year. In 2017,2018 and 2019 the Department of Financial Service approved an increase for EPO Silver plan. 13.2%, is a rate higher than the rate of inflation, 2.5%. . I earn a small salary and this increase creates a hardship for me. The Department of Financial Services must approve this inflated increase. Instead the Department of Financial Services should cap all increases.

A 21% premium hike for our Oxford Metro Healthy NY small group health insurance is unacceptable. We are a small business -- trying to stay afloat in expensive NYC -- and our workers can barely afford this premium NOW, as it is ($607/month). You cannot raise it by 21%! We are putting pressure on you, so YOU put pressure on your suppliers to lower their costs - or cut out middlemen completely - this cannot go on. America's healthcare system is broken, and us small business workers should NOT be responsible for paying for it to be fixed while insurance and pharma CEO's are paid literally MILLIONS of dollars ($3 million last I checked)! This is wrong!

Our health insurance carrier is requesting a 16% increase in our rates for 2020. They already increased our rates 5.7% for 2019, 8.5% for 2018 and 11.1% for 2017. This latest increase would put an undue burden on our company and our employees with our current single payer rate being $1,165.35 per month/per employee. A 16% increase would cost us $1,351.81 per single employee per month and increases exponentially with spousal, child and family rates. An increase like this would make it impossible for us to continue offering health insurance to our 12 employees. We hope that you will reject this outrageous rate increase and request they offer something a little more reasonable. Thank you.

Page 7: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

Rate increases are becoming too frequent and too high. We are a small business already struggling to keep up with the high cost of providing health insurance to our employees. The employees also have a hard time paying their share of the costs. It is time for health insurance providers to make meaningful changes in the industry and not just focus on profits. The burden of costs is falling more and more on the insured, with high premiums, high deductibles and cost sharing. We are against another increase at this time.

We are against the proposed premium rate change. As a small Company, we struggle to keep up with the high cost of health insurance and our employees are struggling to keep up with their share of the costs. The rising costs are fast out pacing the rate of earnings.

Please consider a lower rate increase than the proposed 25.8% that Oxford is requesting. For small businesses like ours, we are limited in the rates that we can charge our clients, and so our annual income increases are minimal, if anything. An increase to our health insurance premium as large as 25.8% will adversely affect our employees who already pay an exorbitant amount to Oxford each month for basic coverage. Please challenge Oxford to find other ways to reduce their costs or work with the health care providers to lower their rates. The small businesses are getting squeezed from both sides, and it will cause great financial burdens to many. Small businesses also do not have the same negotiating power as larger corporations, so we are stuck at the mercy of insurance companies such as Oxford. Please advocate for small businesses and help us continue to provide benefits to our valuable employees by demanding Oxford lower their percentage increase for 2020. Thank you very much for your support.

BS a 17% rate increase is ridiculous. Please fight for the consumer. Its a Billion dollar business taking advantage of us. Its a killer for us its a $2000 a year increase. Cant you all stop this madness.

A 16.2% increase will put my small businesses monthly premium at $3,233.96 a month. This is for a Parent/Child and One Single Employee. I want to keep the type of health insurance I currently have always had, but feel like I'm being Priced out. It's wrong having to pay so much for health insurance and on top of the monthly premiums, having to pay extra for medications with some of those medications being denied by the insurance company. Health Insurance Companies have way too much power and something has to been done. There should be a cap on how much Health Insurance Companies are allowed to charge the customers. FYI for a similar type of insurance on Obama Care, I would have to pay a few thousand dollars in deductibles, not get everything on my current plan and the monthly premiums are basically the same. So Frustrating!

Page 8: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

So Oxford is requesting a rate increase of 15.9 %? Having grown up in Brooklyn during the heyday of organized crime, I can say that loan sharks wouldn't raise the vig that much on an annual basis! Health insurers are worse than the aforementioned criminals in that they operate under the guise of honest corporations. So this is how things will play out: I will have to let full time staff members go due to the exorbitant cost of healthcare coverage, and hire per diem/part time employees going forward. Frankly, thats a shame. I'm not anticipating a meaningful reply, just wanted to vent........

someone has to put an end to: not just the premium rate increase, but at the same time they decrease your coverage's and increase you deductibles and out of pocket expense's. These other factors are not reported to FRS, and certainly never available for us to examine. Just say NO!

We are a small business and have seen premiums rise so quickly over the past 5 years it is hard to keep up. We have seen less and less doctors participating in our plan over the past few years in NYC. These huge increases with less service are not worth the cost. There seems to be no regulation in this area. Employees have had issues finding new doctors in the plan once their doctor has left. They end up paying more out of pocket which negates the whole purpose of having a plan. Services that are covered under the plan sometimes have little to no available doctors in locations in NYC. And those few doctors on the plan are usually booked up and not accepting new patients. This has been the case especially in the mental health area of the plan. It's like having a library card for a library with a dozen books for hundreds of people. Only we pay for it directly and it increases up to 16% this year! In one of the most densely populated cities. Not to mention several employees have had to jump through hoops that the plan sets up to minimize costs for serious health issues. 16% would seem small if plans were actually $100 or so but each employees plan for us is about $1200.00 a month. This plan started around $750-800 and that was a lot then. Clearly any reasonable person would see there is an imbalance in the price of the plan with these huge increases and the services provided. We value our employees and want to keep them healthy and happy and I can't imagine how many other small business are trying to make all this work and need the support of regulations. For the price we pay people should be able to go to pretty much any doctor any time and not be stalled an delayed by the insurance companies money saving tactics. Please look into the rising costs of their executives not just the rising costs they are claiming for providing care. Sincerely,

16% rate increase is an offensive ask, especially when they have been pushing steep rate increases on an annual basis, and I see all sorts of waste and inefficiencies in the system that they should have a better handle on. I'm an actuary, and in the PC world, such inefficiencies get competed out to the best operators. In the HC world, it seems that there is not incentive for HC insurers to invest in efficiencies since they just end up passing on the cost to their members.

proposed 15% rate increase for my oxford insurance policy is OUTRAGEOUS. each year the rates go up, and each year the quality of the insurance and service goes down. I urge you disapprove of the requested rate increase.

Page 9: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

The reason why Oxford wants to increase the premium is because I had which required a surgery and then had some frequent follow-up procedures ( ) ONLY NEEDED in the first year (Part of the process to get rid of

). It has been about two years and is no longer showing, the visits now only consist of a SCOPE to look inside which will now be approx every six months and possibly once per year. Keep in mind that I pay $500 every time I have those making it quite expensive on top of the $1800 monthly I now spend for the Insurance. I Hope this premium rate will not approved since I will not be able to pay otherwise. Thank you for your understanding.

United Health Care/Oxford notified us of a proposed increase of 18.4% in 2019. We are a small company in the New York City area that offers insurance to our employee, with their cost share being 25% of the premium. An increase of 18.4% is outrageous and will hurt our business and the ability to offer health insurance coverage. We implore DFS to reject this increase. Thank you.

I think that an 18% rate increase is extremely unreasonable, especially for a small nonprofit business like ours where our own income certainly does not increase 18% per year.

I am totally against this rate increase. Every year the premiums go up and quality of coverage goes down. Regular blue collar working Americans like myself cannot afford another price increase.

Hello, I oppose the proposed premium rate change of 16.2%. This area of the country is very expensive to live in - from food to housing to healthcare - but salaries do not seem to be keeping up. I very much doubt I will receive a raise that will cover the proposed increase in health insurance this year, and I am already paying a large chunk of my salary for health insurance. If health insurance companies want to keep their subscribers they need to make health insurance affordable. Thanks very much,

1. Oxford Health Insurance, Inc. is not providing sufficient information to justify their proposed rate increases of 17% 2. There is little reason to expect a large increase in medical trend in the year of 2020. (especially for our group) As in fact, our group had no increase in medical trends in the year of 2019, and no increase in the year of 2018, as projected by Oxford Health Insurance.

I am adamantly opposed to the proposed increase of 17.9% on our group's premium. It is cruel and unjust. Rising medical expenses are also affecting individuals and small businesses, and are not a justification to a price gouge.

Page 10: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

A premium increase of 16.7% is absurd!! I cannot afford my deductible to seek treatment as it is! We need a Medicare for All system. Please do not let Oxford raise my rates a whopping 16.7%%. Thank you.

United Healthcare (Oxford) has asked for a 16.2% increase to my premium rate. They have been approved for increases for the last two years. Im asking, as a member of Oxford. That they are not given permission to raise rates for a third straight year.

As a small non-profit organization, it is already difficult to attract employees due to the high cost of our insurance plan. An 18% premium increase will make it impossible to hire anyone who needs health insurance coverage through their employer.

The annual % increase of our health insurance premiums is absurd. I have an and must go to several specialists throughout the year. I feel like I'm being punished for having this condition and forced to pay extraordinary costs on top of the medical problems I'm suffering. Who's receiving this money? The doctors, the hospitals, the health insurance company? I am not advocating for universal healthcare, but the greed of the industry has crossed a line here. Please deny Oxford Unitedhealthcare's request for a 15.9% annual increase for 2020. This rate should match the current rate of inflation only, 2-3%. Thank you.

It seems quite unreasonable that the insurance rates can go up so high. I have had this insurance for over a decade and its being going up ever so often and it more than doubled in the past decade. Now to increase it by the 16 % requested is just not the right thing to do. I most strongly oppose this increase.

I am always trying to provide coverage for my employees but the rates keep increasing. To increase this rate by 18 % is terribly unfair. I will be unable to provide coverage to my employees or the cost will be passed on to them. I strongly oppose this rate increase

Our premiums are high enought! they should be more affortable not increasing by 17.6%

Page 11: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

Please show some backbone and to quote our former first lady Nancy Reagan Just say no I know this will be hard since many of you are probably receiving a nice kick back for looking the other way every year but try. Sound out the letters slowly. NO. See not so difficult. Of course you will do nothing as usual. Probably say you only gave them 1/2 of what they asked for but 1/2 is still to much as we the middle class sink further into the abyss because of every increase you allow by everyone and anyone who asks. To quote our President, we do not need to MAGA because it already is but make it affordable for those who pay more than their fair share of taxes and who pay all of your overpriced salaries and really receive nothing in return. Thanks

My health insurance has been steadily climbing for the past few years to the point I will not be able to afford it anymore. I went from $1900 3 years ago to $2400 a month currently. If the 17.9% increase goes into effect this will make my premiums more than my mortgage per month and be a whopping $2832! This is insane! Please DO NOT PERMIT THIS CHANGE! How about streamlining how hospitals do business and for those of us that are rarely sick do not get the short end of the stick! Thank you for your time and attention to this matter! -

Every year United HealthCare notes their costs have risen and attempts to raise out health insurance plan by large amounts. I would like to object to this rise both due the increasing strains it places on my budget as well as the fact that many analysts believe health care costs are rising by far lower amounts. For example Price Waterhouse's Health Research Institute projects 2019’s medical cost trend to be 6%. This is consistent with the last five years, which have seen trends between 5.5% and 7%. With those statistics in mind it is hard to see why this policy needs to rise 10%+ a year. I would truly hope you perform a detailed analysis with United both to evaluate why their costs are rising faster than average and what can be done to minimize cost rise to policy holders such as myself. Thank you.

This rate increase is grossly overstated. We hardly use our medical insurance and so we know we are underwriting a lot of other people. However, the cost of pharma and the FOR PROFIT status of health insurance companies work against the average citizen. The prices are going up for the sake of Wall Street status and it is becoming more clear each year that the ruling class of this country is disconnected from the majority of the citizens. DO NOT ALLOW MORE OF AN INCREASE THAN WHAT WE USUALLY GET AS WORKERS. 2%

I object to my premium increase. I am a healthy individual and reject your claim that there are increases in the amount of services used.

Page 12: Oxford Health Insurance, Inc. Small Group 2020 Public Comments€¦ · make more insurance more affordable and information about rate increases more accessible. Thank you for your

Oxford Health Insurance, Inc.Small Group2020 Public Comments

The premiums on my plan have been increased by nearly 50% since we started with Oxford a few years ago. They now want permission to increase the rate by 16% for 2020. This is outrageous and unsustainable. I am a and as such I need to have a good medical plan. At this rate of increase the cost of my plan will be close to 100% greater then when I enrolled by 2021. A 100% increase over 5 years is egregious and can force me and many in NY to have to lower the benefits they receive. In my case it could be a matter of life and death due to my history. Please deny their request and allow for something reasonable such as the inflation rate +1-2%. Thank you in advance.

To whom it may concern, I have received notice that my company's health insurance provider is requesting a 13% increase in premiums. I am writing to state that this is utterly unacceptable. Median worker wages have not increased 13% in the state of New York in total the past decade, let alone since the last time a premium increase on this insurance plan was permitted. Oxford Health Insurance is seeking to squeeze more and more out of workers whose real wages shrink year after year and that is monstrous. Given the financial situation of workers in this state ANY increase in health insurance premiums is absolutely unacceptable. Especially considering that UnitedHealth, Oxford's parent company saw a 12% increase in revenue last year, an increase in earnings that the workers of New York state would have to combine together 20 years of pay raises to see. Healthcare is a human right and no private entity should be permitted to hold the threat of death and sickness over people to pad out their bottom line. I expect and demand that the state of New York deny this request. Yours,

UnitedHealthcare and the other healthcare providers in this country have no issue lobbying to keep healthcare as broken and exorbitant as possible. Making the US a laughing stock of the developed world for not only not being able to have universal coverage but in countries where pills, operations, and therapies cost hundreds they cost average American thousands if not hundreds of thousands with many of these technologies and treatments developed here. So my comment it I will always oppose a premium increase. They make enough margin to funnel it into disinformation campaigns and lobby our government. I have insurance currently but honestly I don't think it's worth it to keep it if they just keep jacking up the cost to me saying Medical expenses are rising They are to blame for these issues and yet get to reap all the revenues.

The insurance rates are increasing every year, while we expect the insurance company to find ways of keeping rates reasonable, they are not affordable for small companies or employees that don't make over $100,000 per year. 16% increases YOY can bring monthly premiums very soon to be more than mortgage payments. Unacceptable!

My group rate insurance already costs my family over $25,000 a year, with high co-payments and a deductible. Adding another 18% would result in approximately another $5,000 from my pay. Every year the rates increase 18-24%. These rate increases prevent me for saving for college for my kids, have me struggle to pay my mortgage and other bills, and if allowed to continue will have my family and me looking to leave NYS, as these continued increased costs are unsustainable. Health insurance premiums must be curtailed, and you should deny Oxford's request for an increase.

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i recently received a notice form my insurance carrier that they were requesting a 17 present increase in our health plan coverage this will force my company to no longer provide coverage for our employees . please don't approve this increase thank you

Ever year since I have had Health Insurance with Oxford they have RAISED rates on average double digit percentages and now I get notice of a 15% INCREASE REQUEST.This is untenable and just plain gouging of their customers. How can this be allowed - forcing self employed people to have to go without insurance due to crazy price increases. Please stop this.

15.5% increase is insane. It will literally put us out of business. We can't afford that high of an increase.

I can't afford to pay higher premiums, as it is I'm one of the lucky ones that my company offers health insurance to. They are stating that if premiums keep on going up, we will loose the so called benefit. I pay more than $800.00 monthly thru my company plus co-pays and such. Something has to give.

We are a small business who have been struggling to make our monthly premiums for Healthcare for our employees. These yearly increases are taking a financial toll on our revenue. To even purpose a 16.9% increase is unfair when our premiums and deductible are so high. Over the past 10 years we have had to downgrade our insurance two times to meet the premiums of Healthcare. Please keep this in mind when considering approving this astronomical increase. Thank you.

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June 12, 2019 NYS Department of Financial Services Health Bureau – Premium Rate Adjustments One Commerce Plaza Albany, NY 12257 Re: United Healthcare Oxford 2020 Proposed Premium Rate Increase Objections To whom it may concern: I am objecting to United Healthcare Oxford’s Premium Rate Increase request since our premiums increase every year to renew with the same health coverage. We reduce our coverage in order to pay a lower premium, but the coverage reduction increases our deductibles and co-pays and the premiums are still higher than the previous year. Also note that the executive compensation for United Health has increased 10%-28% between 2015 and 2018. Last year our premiums increased by 3%, even though we reduced our coverage so that the increase would be lower. See below for comparisons: 2015 2016 2017 2018 2019 Average AVERAGE TOP EXECUTIVE INCREASE IN BASE SALARY 22% 28% 18% 10% ? 20% Our Premium Increase (for High Plan) 2% 3% 8% 14% 3% 6% Our Premium Increase (for Low Plan) 3% 9% 3% 13% 3% 6% It seems to me that this increase is not warranted as the top executives’ salaries increase exponentially each year and our increased premiums appear to be funding them. Below is the information regarding our health insurance: Insurer Name: United Healthcare Oxford Plan Names: High plan is the Silver Freedom Non- Gated 30/60/2000/80 PPO HSA 18 Low Plan is the Silver Freedom Non- Gated 2000/70 EPO HSA 18 Coverage: Group Coverage HOIS Plan ID: 85629NY0010272 I would appreciate a response and demand that United HealthCare NOT be granted an increase in premiums. Sincerely,

It is patently absurd to demand a 17.6% increase without any increase in benefits. Oxford is screwing over its insureds YET AGAIN while giving dividends to its investors. Grow a pair and block the increase.

It is not possible that year after year any company whether health insurance or not requires double digit increase year after year after year. Health insurance companies profits are in the billions so how do they require these increases? Our government needs to help and protect us not be in bed with the insurance companies. You are not serving the people as you should. You should all be ashamed!!!

I received a letter from my insurance company saying they put in a request to increase the premium of my plan by 18.2%. They already increase the premium this year and over the past 3 years. I now pay over $900 a month for my plan and an increase of 18.2% seems like robbery. I don’t see how the state can justify letting the insurance company continue to raise the rate again this year by 18.2% when it has already new raised this year. Please reach out with any questions I appreciate your help.

Oxford is requesting an 18.6% increase which is far higher than any cost of living increase and the consumer price index. This will be passed along to the employees and become a burden to our small group as well as myself as a single parent household supporting children. The 18.6% increase is excessive.

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13.7% ??? How can anyone afford that kind of rate increase? It is obvious that something needs to be done about healthcare costs, but the brunt of these costs should not be on our backs. There is no way anyone can substantiate this much of an increase. It is outrageous. You must protect us consumers from this kind of blatant abuse. The healthcare companies are raking millions and millions and executives taking huge bonuses and yet they are proposing such an outrageous increase. 13.7%? !! I believe in capitalism, but I draw the line at abuse. I truly hope you do the right thing and ask the insurance companies to go back to the drawing board if their costs are rising. A rate increase is not the answer. Thank you.

This rate increase is so unfair. Could someone please explain why this burden is being placed on us - small businesses? Are our rates increasing so we can pay for people to get free healthcare? This system is so broken. These rates are astronomical for us. Shame on you. You need to fix this and stop passing the buck to hard working New Yorkers who already pay a ton in taxes.

Insurance companies have been raising their prices at astronomical rates in recent years. The proposed 17.6% raise is ludicrous. They should be embarrassed.

We receive a letter that Oxford is proposing a 14.8% increase on our group's premium. As a small employer in NY, we can not afford to meet these kind of increases and it results on our employees incurring a larger expense for health care. With a standard cost of living increases at 2-3% how can the insurance companies get away with this kind of increase? We hope and trust that NYS Financial Services will block such a high increase. Thank you

Dear Superintendent Lacewell, I write to file an objection on the proposed premium rate increase of 17.6%, recently filed by Oxford Health Insurance, Inc. (OHI). I have the RI2064, CSP32 Metro plan, which is small group coverage through my employer, and our HIOS Plan ID number is 85629NY0010471. I have been a customer for years. I need health insurance because I have three children under years of age and cant event start to imagine what I would do if I lost coverage. If Oxford continues to increase it's cost I wont be able to afford to pay for health insurance. I urge you to fight for the rights of all lower and middle class families. We all have a right to receive affordable health insurance. This proposed rate increase will be a major hardship for me and my family. I believe that my carrier’s profits, administration, and executive compensations costs are too great and urge you to require it to invest more premium dollars into its customer’s health expenses. I strongly support the Department of Financial Services’ efforts to make insurance more affordable for all and information about rate increases more accessible. Thank you for your attention to this matter. If you need more information about my situation, please feel free to contact me at:

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I just started a new insurance policy and they are already trying to increase it by 17.8%! I am already paying a crazy amount for insurance. Please help and protect us!

A proposed 17.8% premium increase for a small business like ours will prove to be a large barrier to hiring further employees. With inflation below 2%, how can there be any justification for a 17.8% increase

In reference to the proposed premium rate changed that has been requested by my health insurance provider (Oxford Health Insurance, Inc.), I object on grounds that the requested 17.2% increase is out of sync with the rate of inflation in the wider scheme of what the cost of goods and services have risen this past year. On a more grassroots level, a 17.2% increase in premiums would add an additional cost of $1,696.86 to our employee benefit costs and would certainly force us to cut our employee's hours and thus create a financial hardship for these affected employees. Please re-consider denying outright this excessive premium rate in this light and in view of the fact that our plan benefits have been curtailed all while deductibles have increased along with a consistent steady increase in premiums for the past ten years.

The proposed increase is unreasonable and unaffordable, I ask that the requested rate change is rejected.

As both a customer and a provider, I would like to submit a grievance. We are a private who not only provides care to Oxford members, but also are a customer of Oxford health insurance for our own employees and doctors. I cannot describe how disappointed I am with the state of healthcare in this country. As a small group, we are taking the absolute brunt of the healthcare costs. A city worker in NYC, of my age (who also makes double my salary), spends less than $150 a month on coverage. Excellent coverage medical, dental, and vision. Where as I am spending close to $400, with a huge deductible, and then a coinsurance on top of that, no dental, no vision. As an employee and manager it is sad to see a 15% increase in my plan, and the plans of employees who will be forced to drop coverage because of this. As a provider, It is sad to see proposed 15-17% increases in your plans. Meanwhile, reimbursement consistently goes down for the same services. Who is getting this extra money? because it most definitely is not the providers, who now have to deal with an increase in minimum wage, rising health costs, and then on top of all this Insurance companies are making the whole system as convoluted and confusing as possible and the only way to stay on top of it is to hire MORE employees. Between networks inside of networks, referrals, authorizations, drug coverage, deductibles, copays, coinsurances, out of pockets, in network, out of network. And don't forget the incentive plans which reward doctors for checking correct boxes on computers, and punish those who don't. The entire system is broken beyond repair. Then insurance companies speculate why healthcare costs are rising. If you ever want to hear further thoughts on this matter, please contact me. However, I promise if rates increase this much we will drop Oxford and also employees will choose to go uninsured, as they just cannot afford this.

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I would like to please contest the proposed premium rate increases for 2020. The rates are already a challenge to meet for many on these plans, and for many in my field (hospitality) the lack of affordable health insurance is a huge issue. I understand costs rise annually, but an increase of 13% is far too high. Thank you

United Health Carr Oxford is extremely profitable, they spend large amount on lobbying and premiums are high with high co pays, this increase is not required

I am writing to file an objection on the proposed premium rate increase of 17.6% recently filed by Oxford Health Insurance, Inc. (OHI). I have Metro plan, which is small group coverage through my employer, and our HIOS Plan ID number is 85629NY0010471. I have been a customer for many years. My husband (who is covered under my plan) and I need health insurance to maintain my current good health but besides that, it is a requirement. This is not a luxury item. I make a non-profit salary and this proposed rate increase will be a major hardship for my family. I believe that my carrier’s profits, administration, and executive compensations costs are too great and urge you to require it to invest more premium dollars into its customer’s health expenses. I strongly support the Department of Financial Services’ efforts to make more insurance more affordable and information about rate increases more accessible. Thank you for your attention to this matter. If you need more information, please feel free to contact me at:

Oxford has alerted us that is is requesting a premium increase of 17.2% this year. This comes on top of increases amounting to about 20% since 2016. Providing good health insurance coverage is an important part of what we can do for employees and for our community generally as it support better health and fewer doctor or hospital visits. However, no business can sustain regular increases on this level. The result of increased premiums will be less healthy employees and their families, and will force us to either reduce our share of premiums or reduce coverage; both of which will result in greater strains on our business, employees, and the general public as public resources will be needed to fill in the gaps in coverage. This increase cannot be allowed to take effect. I strongly urge you to assist us, Oxford, and other health insurers by insisting that the federal government reverse its negative changes to the Affordable Care Act so that more citizens can obtain affordable health care through their employers and through local plans where they do not have access to employer-provided coverage. Thank you.

Oxford is proposing a 17% percent hike in premium, which is completely out of line of inflation, wages and the rising rates in the cost of healthcare. People cannot afford such a drastic spike in rates.

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OHI is proposing a premium rate increase of 13%. This is outrageous. Health care for small groups is already barely affordable for small business owners like myself. I hope you will restrain them from increasing the rates so much. 5% seems more in line with inflation and reasonable increase.

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Name of Insurer: UnitedHealth Group – Oxford Health Insurance, Inc. Group Plan name: , Freedom Plan, CSP06, PPO Platinum Group Number: HIOS number: 85629NY0050026 We are writing to strongly protest the rate increase requested by Oxford for 2019. We are a small group plan. We have employees, and we are all enrolled in this plan. We each pay $1,181.14/month for this plan, and now Oxford is requesting an increase of 15.5%, which would bring our monthly premium to $1,364.22 each—almost $2,200 more for the year. This is absurd, and offensive. Oxford informs us that the main reason for the requested increase is rising medical costs, and they also cite increases in the amount of services used. In fact, we have not had any significant increase in services used. We have mostly used only basic, standard preventive care this year and most of the past 6 or 7 years. We have seen our primary care physicians for regular check-ups and we have had colonoscopies and breast exams. That’s it, and that’s all it’s been for quite a few years. The sum total of all of our medical expenses for the past year probably does not even come to $3,000, and that is what we are paying to Oxford each month. How can that be considered an increase in the amount of services used? Perhaps other groups and individuals are using more services, but not ours. If Oxford is basing our premiums on what is going on with other groups and individuals, then what is the point of our having our own group, for which we pay a great deal more than we would have to pay if we were employed by a big company with a large group of insureds? Based on our current premiums and our service usage, we should not warrant ANY increase at all. We are paying a huge amount per month for mediocre coverage and not using it in any significant or burdensome way. In addition, for 2017, Oxford raised our premiums, with your approval, 8.8%, and for 2018, 5.5%, even though we had no increase in usage, and certainly our primary care physicians did not get any increase in compensation as a result. It’s very hard for us to understand why you approved any rate increase over the past few years, and we believe no rate increase is justified for next year. It is important to understand the context for this increase (and frankly for the outrageous level of our current premiums). As we note above, we are paying $1,181.14/month each in premiums, and we have used very, very little services over the past few years. Oxford is making a great deal of money on us, and now wants to make more, without ANY increase in benefits to us or services for us—we get no benefit from this increase, like better coverage, better service, etc. This increase is totally one-sided, as it always is. The UnitedHealth Group proxy statement for its 2018 annual meeting reports mind-blowing information about revenue, net profit, executive compensation and stockholder return for 2017. According to the proxy statement, during the period in which we will have paid over $40,000 to Oxford for services that cannot have amounted to more than a total of $3,000— 1. The company’s revenue increased 12% (a 33% increase over last year’s 9%!). 2. The company’s earnings increased 14%. 3. The company’s earnings per share increased 14%, and adjusted earnings per share increased a whopping 28% (extraordinary!). 4. The company’s dividend rate increased 20%, following an increase of 20% last year. Shareholders are certainly making out VERY well, even without the increase Oxford is asking for this year. 5. The company’s shareholder return was 15% (more stunning data on that below). But even more importantly, the five named officers made $11,352,513, $18,107,356, $8,587,912, $21,232,550, $9,763,024, respectively. For some of these officer, that represents a near 10% increase in compensation, for one, an increase of 28%, and for one new office compensation of over $21 million right out of the box! While the base salary of the Executive Chairman, Mr. Hemsley, decreased $200,000 to $1,000,000, the base salaries of three of the remaining officers increased 12%, 15% and 16%. Other components of compensation also increased by substantial amounts. In terms of cash incentive awards, the increases over last year were 10% and 25%. In terms of “other compensation” (including matching contributions and payment of various fees), four officers enjoyed increases of 14%, 26% (two officers), and 46%. Those are extraordinary numbers. Mr. Hemsley also has a pension currently valued at $20,459,928. And to top it all off and highlight the absolute insanity of this requested increase, all six of the named officers have contractual rights to payments upon their departure from the company in the event of death, disability, retirement, discharge not for cause, and change in control. It would be too wordy to lay out exactly how much all of these departure payments would be, but here is the basic idea: Mr. Hemsley would get $63-$69 million, depending on the reason for departure; one officer would get $38-$49 million, depending on the reason for departure; one officer would get $19-$25 million, depending on the reason for departure; one officer

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would get $4-$21 million, depending on the reason for departure; and one officer would get $3-$25 million, depending on the reason for departure. DURING THIS YEAR, AND IN FACT, OVER THE PAST SEVERAL YEARS, NONE OF THE THREE OF US HAS GOTTEN ANY INCREASE IN COMPENSATION AT ALL, DESPITE WORKING INCREDIBLY HARD TO RETAIN OUR CLIENTS AND SERVICE THEM WELL. WE ARE SUCCEEDING IN THAT, BUT WE ARE UNABLE TO GET OUR CLIENTS TO INCREASE THE AMOUNT THEY PAY US. We have, however, been forced to pay more for health insurance every year. Why should we pay more for insurance in order to fund the kind of shocking compensation and compensation increases at the executive level at Oxford? Please recognize that these officers have been making this kind of money for many, many years, with increases over the years similar to this year. These people are not hurting, but we as consumers are. We also note that Mr. Wichmann (as the CEO of UnitedHealth Group) is included in the New York Times rankings of CEO Pay (May 24, 2019, Business Section) for the 200 highest paid CEOs of companies with at least $1 billion in revenue. The total compensation reported for him is $18 million. We do not judge Mr. Wichmann for getting a good job and negotiating a good salary for himself. But when he appears on a list of the highest paid CEOs and his company provides weaker and weaker insurance for higher and higher rates, that is not an appropriate time to demand further premium increases. Increases to premiums might be reasonable if the quality of the insurance were going up, or if the company were losing money, or if the company developed an innovative approach to healthcare that benefited insureds and healthcare providers—but NOT when the company is raking it in and paying their executives extraordinary and ever rising compensation. Here’s another shocking piece of information revealed in the proxy statement: the stockholders of UnitedHealth Group earned a return of 15% on their investments in 2018, and a return of 122% on their investments over the period 2016-2018, and a return of 258% on their investments over the period 2014-2018. That’s incredible for the stockholders, but again, why is it reasonable for us to fund that level of return, particularly when none of us is enjoying any increase in compensation for all of our hard work? Wouldn’t a return more in the range of the inflation rate or slightly higher be more reasonable? If Oxford can generate that kind of return for its investors, that’s great, but it should not come from increased premiums from us. And please note—those levels of returns were generated during years BEFORE the rate increase that Oxford is requesting now. If Oxford were to get no rate increase at all from us now, how much would stockholder return and executive compensation be diminished? It’s hard to imagine very much. Oxford and all the other health insurance companies state repeatedly that medical costs are increasing, but it’s very unclear what the nature of that increase is, and Oxford does not specify it either in the notice they sent us or in the further information posted on their website and yours. And it’s worth pointing out that with all these medical costs that are supposedly increasing, the company is still making monumental amounts more year after year. Where is the impact of these so-called increased medical costs? To us and most other ordinary people, it appears that the increase in medical costs is more due to health insurance companies gouging their customers and beating down health providers than to any actual increase in the cost of medical services. At the current time, there is no reasonable justification for the health insurance industry to be a for-profit industry, but until Congress acts to eliminate any profit motive from private insurance, or establishes a single-payer system or public option, it is up to you to balance the legitimate needs of these companies with the needs of their customers. The system is seriously out of balance in favor of the insurance companies. You have the power to shift it a little bit back toward the consumer. We expect you to do that. Respectfully,

The rate increase of 17.6% proposed is exorbitant and would be a financial hardship to my small business.

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We received notice of a 17.1% increase to our current policy. This increase would force us to require a higher contribution from our employees or switching to a plan with less coverage. Neither of those options are productive in trying to retain our employees or to continue to be a successful business. We are over 50 people, but are are subject to the community rating for all small groups, we are not rated on our groups' members. This rate of increase is not in line with the intent of the ACA, but is reminiscent of increases prior to the requirement that insurance companies file their increase requests with the state.

Yet another double digit rate increase is absurd. Rates are outrageous as it is and we only keep paying more in premium for less and less coverage. THIS INSANITY HAS TO STOP! Say NO to any rate increase.

We received notice of a 17.8% increase to our current policy. This increase would force us to require a higher contribution from our employees or switching to a plan with less coverage. Neither of those options are productive in trying to retain our employees or to continue to be a successful business. We are over 50 people, but are subject to the community rating for all small groups, we are not rated on our groups' members. This rate of increase is not in line with the intent of the ACA, but is reminiscent of increases prior to the requirement that insurance companies get approval from DFS.

We received notice of a 16.5% increase to our current policy. This increase would force us to require a higher contribution from our employees or switching to a plan with less coverage. Neither of those options are productive in trying to retain our employees or to continue to be a successful business. We are over 50 people, but are subject to the community rating for all small groups, we are not rated on our groups' members. This rate of increase is not in line with the intent of the ACA, but is reminiscent of increases prior to the requirement that insurance companies get approval from DFS.

We just received notification that Oxford is asking for a 15.1% increase in its premiums for next year. How can this possibly be allowed? The premiums go up exponentially every year without explanation or cause. This is a high deductibility plan whose premiums are getting too expensive to bear. How can the State allow this? What is your criteria for approving? Does the State ever just say no? The consumer would do better in an open market WITHOUT government intervention where the insurance companies actually had to compete for business. By indiscriminately granting these increases, you do not allow the consumer to shop around because EVERY company gets the increase they want. Please help the consumer and allow some competition!

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I received a letter that there is a request for the premium to go up 16%! This is incredible, as this is upon a large increase last year and the year before and so on. I am getting less coverage, higher co-pays and deductibles with this higher premium. I hesitate to go to a doctor due to these high costs. I don't see how this request benefits your clients as in the long run preventive care isn't taken care of properly which may result in higher costs to you. I protest this increase. Thank you.

It seems Oxford is asking for an absurdly high increase in premiums of 17.8%. In reviewing many of the current requests, it seems this request is VERY HIGH. Hopefully NYS can see its way clear to DENY THE INCREASE. The premiums are currently what I would consider to be unaffordable. If this increase goes through I could be forced to drop coverage for employees or let employees got to have the cash available to continue to maintain coverage. PLEASE REJECT their request. Thank you.

The requested rate increase of 13.2% would be devastated for small business owners. Such a increase would essentially make it impossible to offer adequate Health Insurance coverage to our employees. The current cost is prohibitive as it is, forcing small businesses like ours to cut back or eliminate other employee benefits in order to cover these costs. Small business should be protected from these massive propose increases. Our employees are in no position to shoulder these cost, but at the same time they have to secure their family health and welfare. DFS should not grant this requested increase at this time. There is no justification for the insurers requesting this increase. They are still making aprofit base at the current cost structure. PROTECT OUR SMALL BUSINESSES. Regards,

I am NOT approving of the increase in premiums. It is NOT AFFORDABLE and UNFAIR for small businesses and workers to pay such high premiums. Please DO NOT approve this proposed increase.

Hello, I would like to comment on behalf of my employer, My employer is a small company, and a 13.2% prposed percentage increase is astronomical, and will severely negatively impact my employers, and possibly my employment. The business is constantly struggling to pay bills, and this increase in no way reflects natural inflation or any reasonable change to the premiums. Please disapprove this rate increase. My employment may depend on it. Thanks,

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We recently received a letter informing us that Oxford Health Insurance, Inc. (OHI) is filing a request with the New York State Department of Financial Services (DFS) requesting a change to our premium rates for 2020 and, if approved, the percentage change to our group's premium would be 18.2%. This is ridiculous! Oxford is the health insurance provided to us by my husband's employer and although we have been pleased so far with the service/coverage they provide, an almost 20% increase in the group's premium in one year is outrageous. Perhaps Oxford Health needs to do some internal cost-cutting before they lose clients due to ridiculous premium increases such as this one.

Medical cost inflation for the past year was projected to be 7.2% in 2018, compared with an average of 6.8% in 2017. Oxford is seeking an increase of 17.2%. This bares no relationship to actual cost increases. Certainly, the consumer should not have to absorb the insurer's operational costs which are no doubt inflated. Oxford has no incentive to curb its own administrative costs if they are granted absurd increases in premiums.

I work two jobs and go to school. I am barely making ends meat. I cannot afford to pay an increase in my health care. I am barely able to cover the premium and copays as it it. I do everything I can to save money but this would break me. I have to get every week. I need surgery. I have to see specialists often. An increase would be detrimental to my life. It will literally break me. I am struggling and barely making it pay check to pay check. My and unable to work. My lost his job months ago and cannot find a new one. An increase was already done last year without warning where my copay went from $60 to $80. I need to see these doctors and my medications to breathe. I need which means I will be out of work. Please do not go through with this increase. You will hurt so many people including me, the laborers of this country that help keep it on track.

We are a small start up company with employees in a highly competitive segment of to help people with and assist in for pain management. To attract highly specialized we offer a comprehensive benefits package, which includes insurance paid by the company up to 85% with the employee participation at 15%. An increase in premiums at our stage of company development would be critical and create an undue hardship, as we are just getting started. The DFS denial of a premium increase for 2020 would be a God-sent to us, although we are aware that this may not be practical. However, your determination to keep the increase to a minimum would be very much in line with allowing grass root companies to thrive in the State of New York, supporting commerce, employment of residents and increasing public health awareness and benefits.

I strongly oppose Oxford's proposed 13.4% increase. As a middle-man between me and my doctor, they have added NO VALUE to my access to healthcare.

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I am writing to encourage DFS to reject this rate increase. My health insurance is severely limited and filled with red tape. I would look more favorably on a rate increase if I could use my insurance more freely. As it is now, I am rarely in position to adequately use my insurance when seeking medical services and the amount of information given about how to be a good consumer is mind-bogglingly scant. I cannot tell in advance what is covered, what is not, why, or what the final price will be. Why should I be expected to approve a rate increase on insufficient health insurance?

This proposed increase would be a tremendous hardship to our business and our employees. Our employees pay half of their premium and few if any would be able to afford this increase.

The 15% rate increase is outrageously high and gouges captive customers. Please reverse and lower this amount.

I am currently paying about $1,292.14 for medical and $89.28 for vision and dental for mysmall business operation monthly. This also includes a $6,000 deductible before I can even start using my medical benefits! Oxford/UHC has been increasing our premiums annually now with less and less benefits provided and more and more benefits challenged. Our doctors are now complaining as well as they are not getting much paid back. While this is happening, the CEO and executives of Oxford under the charge of United Healthcare are getting outsized bonuses and even more outsized salaries at the demise of small business operators like myself who are the true engine of growth and revenue for our country. Stop hurting small business owners and stop pandering to your deep pocket lobbyists and donors in healthcare. Start taking care of your constituents and start acting on your campaign promises to take care of the little people. If illegals are now given more benefits than law abiding US citizens, be forewarned that you, the incumbents in BIG GOVERNMENT will pay highly come election time. Change will happen. And it will remember the choices you made for WE THE PEOPLE. So do the RIGHT THING.

I'm writing regarding possible premium increase 2020. This is not an option 15.6% upward each year is impossible to keep up with , I can not afford this and must have medical. Please remember the working people that barely afford there bills . Thank you

I have had a Healthy New York policy with Oxford for the past several years and am outraged about the 20.7% proposed rate increase. Providing health insurance for my family and employee is already a financial strain. Oxford is requesting a much higher percent increase in premiums compared to other insurance companies listed. This is based on their claim that projected claims will increase. In fact, healthcare costs have stabilized overall and my family/employee have actually had lower healthcare costs during 2018 and 2019. Such a large premium increase is not sustainable.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

I strongly disagree with another large increase in the premium rate. It is already very high and expensive for our small business and this may cause us to have to change insurance companies and may hinder our ability to provide insurance for other employees.

We just started providing insurance to of our employees, the proposed 24.4% increase is outrageous! This will most definitely keep us from providing insurance to any other employees and we may have to change insurance companies or stop providing insurance all together.

A 17.1% increase is outrageous. Last years double digit increase was enough. Oxford continues to profit on this plan. We are not big health consumers, just a small business trying to provide decent insurance

The proposed 16.2% rate increase is OUTRAGEOUS. The plan is very expensive at it is and Oxford wants to raise the premiums even higher?? PLEASE HELP US. My family and I can hardly afford what we are paying now for this insurance. If you allow Oxford to implement this rate increase you will definitely be causing financial suffering within our household. While I understand insurance companies are in business to make a profit, it is also unfair for struggling middle-income families like ours to pay such an astronomical amount in premiums. Meanwhile CEOs like Charles G. Berg are making millions of dollars each year! PLEASE, PLEASE, PLEASE (I'm BEGGING you) do not allow this rate increase to take effect. You will be helping us if you don't. You will be hurting us if you do.

I am writing to voice my complaint about the incredible greed of United Healthcare Oxford of New York. They continue to raise our policies by over 10% year after year, for ourselves as well as employees, passing off the rise in medical expenses on to the customer, while continuing to make record profits. In these already difficult economic times, I urge you to deny this request. As myself and my wife are small business owners, we will be forced to move to a more cost suitable state if this continues. Thank you,

Oxford Health Insurance is proposing a 15.5% rate increase on our small group plan premium for 2020. This is an exorbitant increase amount, far beyond any metric for the U.S. rate of inflation (which is generally around 2%). This 15.5% insurance increase would adversely affect our small business. Since 2000, health insurance rates have escalated at extreme rates each year-- the increases have added up to an amount that is crippling our company. In order to keep a plan that our company can afford, we have had to reduce coverage options-- which results in higher co-pays and higher deductibles-- to the point where the insurance plan doesn't even cover that much-- there are a lot of out-of-pocket expenses PLUS the high premiums. So the proposed 15.5% increase is just shockingly high and unsustainable for small businesses. I hope the DOF will reject this extreme increase and opt for one that is in line with the US inflation rate of 2%.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

We have seen Oxford Health Insurance's premium rates increase substantially since 2000 to the point where it's a significant burden on our small business. Oxford is proposing a 15.5% increase on premiums in 2020, way beyond the US rate of inflation. This is way too high given that none of the health insurance benefits will improve -- the co-pays and deductibles will still be the same. The plan we have is very basic -- we already pay high co-pays and have a high deductible. Our company can not easily absorb the 15.5% premium increase. We have tried to provide health insurance for our employees as a full benefit, but with an increase like this we will have to ask employees to contribute pay for the increased costs.

This increase would result in an approximately $400 per month increase in my family health insurance premium. THAT IS ALMOST $5,000 FOR THE YEAR. WE CAN'T AFFORD THAT!!!!!!!! I have a son going to college in The increase we suffered from last year caused us to increase our deductible in order to keep the rates close to what we were paying in 2017, which costs us more than just the additional premium. All our other medical costs came out of pocket and we still paid more for our health care. IT IS CRIMINAL THAT THIS INSURANCE COMPANY IS REQUESTING A RATE INCREASE AGAIN THIS YEAR. 17.9% IS ABSOLUTELY UNCONSCIONABLE. IF DFS APPROVES THIS, OR ANYTHING CLOSE TO THIS AMOUNT YOU ARE NOT WORKING FOR THE BENEFIT OF THE PEOPLE OF THIS STATE. WE ARE ALL SUFFERING TO AFFORD HEALTH CARE AND WITH ALL OUR OTHER LIFE EXPENSES ON THE RISE WE WILL BE FORCED TO CHOOSE INSURANCE OVER OTHER BASIC NEEDS. OUR QUALITY OF LIFE IS SUFFERING AND BY DENYING THIS INCREASE YOU ARE PUTTING MNY PEOPLE AT RISK OF NO, OR INFERIOR, COVERAGE. DO NOT DO THIS. THIS IS SO IMPORTANT. PLEASE CONSIDER YOUR CHOICE AS A MATTER OF LIFE AND DEATH...

personally speaking, since Oxford has saved hundreds of thousands of dollars in providing for his care. I find it hard to believe that there has been an increase in the amount of medical services used. We can’t be the only ones. 15.5% is unconscionable.

Our passed away This alone has saved Oxford hundreds of thousands of dollars. To suggest the amount of services used requires a 15.5% increase in premium is ridiculous.

Our premiums are being requested to go up as high as 13.4%! United Healthcare, Oxford is already an unaffordable, unsustainable healthcare choice for me and my employees at We are against the rise in costs and hope the NYS Department of Financial Services WILL NOT approve increases for this plan going forward. The provider must find another way to implement care without making the consumer absorb the cost!

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

I write this comment in my individual capacity as an Oxford customer. My views do not reflect those of my employer. Oxford proposes to raise its insurance premium by 16.2 percent. Merely a casual glance at employment and wage data shows that this is twelve times last year's growth in real average hourly earnings (1.3 percent, per BLS) and five times the average pay raise employees will receive this year (3.1 percent, per Aon). Worse, this hike comes as the cost of a rental unit in Brooklyn, New York, where many plan members live, remains at a record high (per Zillow). Amidst this background, the simple fact is that a 16.2 percent increase in health insurance premiums will mean fewer people can afford insurance and basic healthcare. Perhaps this would be understandable if Oxford's cost of doing business had also risen. But according to the most recently available financial data, gross profits for Oxford's parent company, United Healthcare Group Inc., grew by 14.5 percent between December 2018 and 2019. According to the most recent quarterly statement, earnings-per-share were also up by more than 20 percent, and net profits by around 12 percent. Oxford is experiencing no hardship. A premium hike means its customers will. If DFS believes itself to be a serious regulator -- the kind that Superintendent Lawsky hoped it could be -- DFS must closely scrutinize the impact Oxford's perfunctory rate hike request will have on customers. After doing so, DFS must ultimately reject it. Sources: -https://www.bls.gov/news.release/pdf/realer.pdf - http://aon.mediaroom.com/news-releases?item=137752 -https://www.zillow.com/brooklyn-new-york-ny/home-values/ - https://finance.yahoo.com/quote/unh/financials/

A 15.3% increase on a premium that is already outrageous in comparison to the services covered is unconscionable. We already pay plenty out of pocket WITH health insurance coverage. I still owe over $3,500 after THREE YEARS AGO (about half of my max out of pocket at the time). A 1%-3% or 5% increase even would be tolerable, but many people are not even getting cost of living increases in salary in NY let alone a 15% increase. Maybe you could take look at your own budgets and cut waste there before you expect the consumer, who is bound by law to have health insurance coverage, to make up the difference.

Hi, I'm not sure what makes the insurance company to increase premium to 16.7%. If it goes on increasing like this then we can't afford any more health insurance State needs to regulate or restrict not to make any increase of more than 5% per year Thanks

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

As an employee of a small business, I am solely responsible for paying my premium, which is already just shy of $1000/month. The proposed increase is an additional 17.4%. Despite choosing what is supposed to be a comprehensive plan and paying a hefty premium, this insurance plan further inflates the cost by refusing to cover services and medication at a reasonable rate -- meds that were covered in full my previous policy with less expensive premium, lower deductible, and no prior auths. There is no way to calculate these unanticipated hidden costs (i.e., costs that will seemingly be covered per policy description, then are denied once submitted) until the situation arises. To say health care costs are rising and thus insurance companies must raise premiums is outrageous to those of us who are already paying such exorbitant prices for our care. We pay for insurance to have our care covered, and as such an increase of 17.4% is completely unwarranted when I am already fighting to get my care covered by my current policy. I seriously hope you will reconsider raising the premium, as healthcare costs are already a tremendous strain on individuals like me.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails.

ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails.

Please see the attached. Thank you.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

I oppose any increases to premium rates for 2020 due to the fact that the Federal Government has done everything in its power to take away people's access to health insurance, and has made it more expensive for those who do have coverage. Also, wages are almost completely stagnant and the cost of living has skyrocketed. There is no justification for any increases to premiums

Dear Sir/Madam, I am writing to lodge a complaint about our proposed rate increase with Oxford. We chose a comprehensive plan with the largest network as well as out of network coverage and have been members since February. We have still been paying large out of pocket costs to out of network providers without receiving full compensation on the deductible since Oxford only acknowledges payment amounts they deem “fair and reasonable” rather than the amount we actually paid to the doctor or facility. My and needs to see specific doctors who are not part of their network, which is why we opted to pay for a more comprehensive plan. Now I received a letter stating that our policy rate will increase by 17.4%. This is unacceptable and should not be allowed as it is unfairly targeting those with who need to see their doctors more frequently. I am appalled by their deceptive business practices and request that this rate be re-evaluated. Thank you.

Hello. Our rates have gone up by increasingly higher percentage rates each year since 2016. It is now (since October 2018) 20% higher and we are at our affordability limit. If the rates jump yet again, especially a whopping 18.2% as suggested, I do not see how our company can afford to cover our employees' healthcare anymore. They are all really good people and I would hate for them to lose coverage, but the fact is with with the consumer goods market heading into a downturn and our increased costs due to tariffs and duty rates, our company simply does not have an additional twenty thousand dollars a year to pay for employee coverage and we will have to cancel the policy, leaving all our employees without healthcare coverage. I have spoken with other small business owners, and they are in the same boat. Please do not grant Oxford's requested increase, which would cause irreparable harm to New York State small businesses. Thank you.

The rate increase that Oxford is requesting is not fair. We are a small family business and the health insurance rates that we are presently paying is a lot already and they want to increase even more. Sorry but very unfair

I appreciate the ability to comment on this issue, so thank you for allowing that. I understand the reason for the rising medical expenses, but already find health insurance to be so expensive, especially living in a state and county with such high taxes. Please don't raise the premiums next year without any clear benefits.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

I am quite angry Oxford wishes to increase my insurance premiums by 13.5%! I cannot sit by and just allow it to occur without saying something. I already have a several thousand dollar deductible which I fall farther and farther behind on paying each year and co-pays that are ridiculously high! I have decided now NOT to get care I may need for myself and my wife because we can no longer afford to pay the medical bills! These health savings plans STINK! Most people I know live paycheck to paycheck and cannot afford to save NO extra cash to pay medical deductibles! The cost of food and basic necessities alone keep skyrocketing each year and there is NO WAY I can afford the added insurance costs on top of it! I Have depleted any retirement savings I had accumulated a long time ago and have no means to save for it any more. I am years old and my chances to be financially secure when I retire now are non existent! I basically cannot retire - EVER! A large part of this is due to the ever increasing cost of my medical bills!!! So I say NO!!! to this increase. What ever reasoning is given for it is meaningless to me if I cannot even use the plan because it costs too much!

Health care costs are getting excessive. Its time for the healthcare companies to find efficiencies rather than continue to bang the consumer over the head. Please deny this request from Oxford.

We have a small company, only employees. We I received Oxford's notice of proposed rate increase - almost 18% - I nearly fell out of my chair! That's a huge annual increase for a small business like ours. It amounts to almost $65,000 extra per year. I urge you to limit this increase, for us and for all the other small businesses out there. It's a shockinghike for a single year and will significantly affect our bottom line. Please help us stay solvent so that we can grow our business and continue to employ as many New Yorkers as possible.

I would like to know about the Premium Rate change of 17.9%, how does this benefit me ? will the deductible, co payments., etc be higher ?. Thank you in advance

Oxford is requesting to increase our insurance by 15.6% for 2020! That is extremely high. We are already almost paying $3000 per couple per month. We strongly disapprove of raising it by this amount. We are a small business partnership.

I am a small business employer that pays for health insurance for 3 families. If the Oxford health plan proposed rate increase of 17.5% is approved, my monthly premiums will increase to $6,000 per month, which I cannot afford any longer.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

June 17, 2019 NYS Dept of Financial Services Health Bureau – Premium Rate Adjustments One Commerce Plaza Albany, NY 12257 Re: United Healthcare – Oxford, Notice of Proposed Premium Rate Change, PR13101, CSP03, PPO Platinum, 85629NY0050012 – Small Group coverage We received a letter dated June 5 from the above referenced carrier announcing they are requesting a 15.5% rate increase for next year’s premium for our policy. This is on top of increases of 5.76%, 8.25%, 3.85%, and 6.26% the past four years. If approved, our health care insurance costs will have gone up 39.62% in 5 years – on average 8% per year while the Fed has been telling us inflation is below 2% per year.

To translate these increases into dollar terms, that means that our health premiums went from $29,892 in 2015 to $43,870 in 2020. That is completely unsustainable for any small business to bear. This most recent requested premium increase of 15.5% should be denied completely. Under any measure, this is a ridiculous pace of premium growth. We are writing to you as the governing oversight body to demand that you carefully inquire and make United Healthcare –Oxford substantiate not only the reasons behind such a premium increase request, but to also inquire what steps the company is taking to reduce cost overall and hold the line on such increases in the near and longer term. This type of burden on small business should be fought vigorously by the State, and companies that apply for such persistent increases must be held accountable or refused in their requests for approval.

In your consideration, please evaluate how the carrier has held the line on executive compensation, increases in administrative overhead costs, and other non-direct costs of providing coverage. Has productivity increased at a reasonable rate or do they just feel they can arbitrarily pass along all costs to the rate base, regardless of managerial largess? This must be considered in these cases where cost increases excessively burden the small business owner. Please update us as your inquiry progresses. We are available to discuss this matter or testify at rate hearings at any time.

Sincerely,

United Healthcare/Oxford's request for a 17.6% date increase on a small group plan is patently absurd. They are in no way adding any increased value, and, in fact, continue to nickel-and-dime their insured for every expense they can. If they feel their costs are too high, they could start by ending their most egregiously wasteful practices - such things as mailing out multi-page explanations of benefits for every prescription refill or doctor's visit. My sense is that these insurer's know the gravy train is nearing it's end, and are looking to profiteer in the most flagrant way - on the backs of owners and employees of New York's already struggling small business. I urge regulators to reject Oxford's absurd request.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

I am writing a comment regarding the propose premium rate change to bring awareness of my disapproval. An increase in my rate will drastically affect my financial stability. As of now, the expensive cost of my health insurance does not allow me to exercise much financial freedom. If the rate is changed, I will be following up with steps on how to terminate my health insurance and will not be renewing my health insurance under this plan in the future.

We are in receipt of a notice from Oxford Health Insurance in relation to a Proposed Rate Change of 16.2%. We as a company have been covering our employees on a health plan for about years. Each year we have faced what we consider to be large cost increases due to changes in healthcare and healthcare premiums. We have faced anything from about 8%-20% rate increases over the course of the years. This has been an even more significant negative burden on us since we have been placed in the small group category. As a small company we face little to no negotiation power with the insurance carriers in relation to coverage costs. We struggle each year to listen to options for our employees that provide them the care that they need at a rate that is affordable to a small company. Are there any exceptions to rate increases for those in a small group category? Month to month expenses continue to rise. We remain an independent practice and do not have the power that the large networks have to negotiate lower premium rates for employee insurance plans. We also do not have the power to negotiate for higher reimbursement rates for the services we provide to each patient. We are being punished for our small group status at both ends. Cost and collections. We ask that you please consider these burdens when reviewing requests for rate increases by the carriers.

We just started giving our employees insurance. A rate increase of 24.4% would force us to reconsider our ability to provide this insurance. We would not be able to handle this increase.

I'm the managing director for a small nonprofit with fewer than full time employees. We received word that the proposed increase for our group premium would be 17.1% which would put this year old nonprofit in financial danger. It's ridiculous that our rates could go up this much and I've heard from other nonprofits that this happening to them as well. Thank you for your time.

Oxford has submitted a request for a 13% increase, and its insane and unacceptable that Oxford has a habit to try to get double digit premium increases every year. Our company, tor educe the premium increase typically changes the benefits, such as higher deductibles etc. to keep premiums ,lower, but the net effect is increased medical cost. How can Oxfords costs increase double digit every year, when a normal worker may gets 2% pay increase only. Especially as pressures are on the insurance companies to make healthcare more affordable!! Not acceptable

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

I strongly object to insurance companies driving up their premium rates. They are the highest in the world. Healthcare cost is ballooning and hurting businesses and individuals. This is something we need to learn how to do right as a country.

To whom it may concern, I strongly object to the rate increase requested by UnitedHealthcare Oxford (Freedom Network). A 16.9% increase is ludicrous and simply not feasible for a young professional such as myself. The cost of living here in New York is high, especially in . Rent alone is nearly half of my earnings after taxes. A premium increase this high would put my strict, modest budget in the red. Though I am already employed 40 hours/week and spend 10 hours/week commuting, this would force me to take on additional part-time work. I say this to illustrate the impossibility of these rate increases year after year, and the way they would directly impact the livelihood of myself and other young professionals. Rate hikes such as these assume that there is a budget flexibility that most people under 35 absolutely do not have. We all have student debt and wages are abysmally stagnant. I need insurance because of and due to I strongly support the Department of Financial Services’s efforts to make more insurance more affordable and information about rate increases more accessible. Thank you for your attention to this matter. Thank you for your time,

The Oxford coverage and service is abysmal. Even when coverage is offered it's not sufficient. The idea that they should be allowed to raise rates is inconceivable. Health care is already, by far, the largest regular expense we all deal with—they should be required to provide actual value for all that money! Please do not allow a rate increase.

To Whom It May Concern, As a small business owner, I are trying to make ends meet from quarter to quarter and with the percentage increase being proposed, it would force me not be able to offer health insurance to my employees. The fact that every year insurance companies push to raise their premiums but keeping the deductibles the same, if not raising them, is not right and down right extortion. Please don’t allow this raise to occur. Thank You

The CEO of UnitedHealth Care was paid $18.1 million in 2018, which is 86 times the salary of the U.S. Secretary of Health and Human Services. See: https://www.bizjournals.com/twincities/news/2019/04/22/unitedhealth-ceos-pay-passed-18-million-in-2018.html We urge the State of New York to reject any health care rate hike for UnitedHealthCare, especially the truly obscene 16.5% hike they have requested.

We oppose the outrageous increase of 14.4% percent in strongest possible terms. It is above any averages and not justified whatsoever. We will have to cut benefits at our company or letting people go. That is against NY State's policy for business advancement and development.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

Friends, I do not approve of a 16.5% rate increase for this health insurance plan. Our premium rate just went up at the start of the new enrollment period May first without any additional benefits - as it has every year. With my employer's contribution to our group plan, I currently pay $185.38 per week for coverage for my husband and myself. This is 24% of my gross pay. There is no way I will be receiving a 16% increase in salary to cover the difference. I strongly encourage you to consider the just-above-minimum-wage salaries of the employees paying into these plans before granting these overpaid corporations more of our hard-earned wages. Sincerely,

My insurance company is proposing a 15.8% increased rate change. I suspect that such a ridiculously high rate hike will not be approved, but I want to be sure to add my voice of dissent. Oxford Health Insurance makes a very nice profit as it is. They certainly don't need to make any more.

I am opposed to the request filed by Oxford Health Insurance to increase the rate by 18.1% This insurer is the largest in the country, with revenue over 2 billion dollars in 2018. The Social Security Administration cost-of-living increase was 2.8% for 2018. An increase of 18.1% presents a real economic hardship to working individuals and families and it seems designed to protect the profits of a health care industry which is costly and difficult to navigate for the very people it issupposed to be supporting (see the ProPublica article Why Your Health Insurer Doesn't Care About Your Big Bills from May 25, 2018). Please deny this request for a rate increase.

A proposed increase of 16.4% is unconscionable, untenable and unacceptable. It is pure corruption. When hard working people like us can't afford health insurance, there is a more serious crisis than anyone even talks about. I want answers ASAP.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

doesn't approve the percentage rate change in our premium of 16.5%

The requested percentage change to our premium is a 13.5% increase. This is a large increase, and not reflected at all in general increases in wages. Every year premiums go up and services covered go down. The main reason for the increase given by UnitedHealthcare Oxford are rising medical expenses. However these increases cannot just be passed on to group rates. It puts an undue burden on businesses/ insureds. The insurance company must negotiate better deals with doctors/medical service providers and trim their own expenses.

I just got an increase letter of 17.5 % on insurance with United Healtcare Oxford. I'm paying $860 per person for me and my wife - that $1720/month!!!!! Now they want over over $2,000.00/ month!!!!! I'm year old guy who does not even go to doctors office!!!!! Whoever signed and agreed to this increase is a criminal and needs to be put in jail for racketeering. HOW DARE YOU ALLOW THESE CRIMINAL INSTITUTIONS CALLED INSURANCE COMPANIES TO ENSLAVE US!!!!! I DEMAND TO KNOW THE NAME OF CORRUPT PEOPLE IN NEW YORK GOVERNMENT WHO PART TAKE AND APPROVE THIS CRIMINAL ACTION. WHEN WILL THIS INSANITY STOP!!!!!!!!!!!!!!!!!!!!!!!!! HAVE YOU ALL NO DECENCY? I WON'T EVEN MAKE TILL 50 BEFORE I WILL NO LONGER BE ABLE TO AFFORD INSURANCE!!!! INSURANCE I PAID IN, FOR MY WHOLE ADULT LIFE. I WANT NAMES AND CONTACT INFORMATION !!!!!!

Hello, I'm writing in response to my Oxford UnitedHealthcare requested rate change of 17.7%. I am years old and am paying over $440.00 a month for this plan. This is the most basic plan my workplace offers. I make 60k and this accounts for 15% of my paycheck. I cannot believe it is even legal to charge this much for the most basic healthcare. This is robbing me of my ability to save money for my retirement or an emergency. I urge you to please restrict this rate change. I will not be able to afford it and will be left with no choice but to cancel my health insurance and I really, really do not want to do that. I know this is the case for others on this plan as well. Thank you,

My small business insurance premium has been skyrocketing, going up 15% every year. We are currently paying $3,266.91 for three employees which comes out to be $1,088.97 per person. The insurer's proposed increase of 15.6% means another $510 increase from what we are paying now which will be $3776.55 monthly = $1258.85 per person. This is putting a strain on our small business. Please do not approve of this premium increase as we are having a hard time as is keeping up with the premium payments. Thank you for your consideration in this regard.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

The rate adjustment is VERY high, and I don't believe our usage of the plan reflects any sort of added risk that needs to be adjusted for. One person on the plan who is older has now entered Medicare and will no longer be on the plan. The remaining family plan chosen should not have to have their premium go up by such a staggering figure. Medical expenses as a whole are not going up 18%, so why punish the consumer trying to protect their family? I ask to please have this reconsidered, and an increase of a figure that is actually reasonable.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

June 21, 2019 In re: Oxford/UnitedHealthCare Proposed 2020 Premium Rate Increase EPO Platinum, 85629NY0010336 To whom it may concern: I write as the negotiator, buyer and plan administrator for, as well as family member of a covered individual in, my firm's Oxford / UnitedHealthCare Group Health Care EPO insurance policy. I have written each year since 2011 to protest what were in each case egregious proposed premium rate increases in Oxford Health Insurance Group EPO Plan rates. This year, UNH's 16.6% demand is among the most egregious, my response to and contextual comments on which follow. On June 18, 2019, we received notification dated June 5, 2019 of a proposed 16.62% increase for 2020 group premium rates. This 16.6% rate of increase is -- once again -- unwarranted, unconscionable and increasingly unaffordable, despite the coverages being more restricted and out-of-pocket costs trending unfavorably for the covered individuals. I am outraged and adamantly opposed to United Health Care / Oxford proposed 16.6% premium rate increases for 2020 Group EPO Plan policies and am similarly opposed to any further grant of rate increases to Oxford / United Health Care -- PERIOD -- for the reasons I will specify following. 1./ The proposed premium rate increase represents the latest in NINE CONSECUTIVE mid to high DOUBLE-DIGIT (11-24%) per annum rate increases in nine years. Since 2008, our current New York Group rates -- for increasingly limited plan designs of declining actual value with significantly higher medical and pharmacy co-payments -- have cumulatively exceeded a 155% increase in premium rates (an 11.0% cumulative p.a. rate) -- for ever-more restrictive plans -- which Oxford proposes to increase by a further 16.6% this year. 2./ All the while, UNH's stock price has soared -- thanks to increases already granted by NYS DFS. 3./ Speaking for my group, usage, claims and plan utilization have DECREASED sequentially for this same period – opposite to the rate increased granted over this period. It is also my understanding that reimbursement to service providers and physicians has decreased, despite increases in subscriber rates, and increasingly delayed and subject to higher physicians' administrative costs to recover. 4./ While Oxford / UnitedHealthCare is a for-profit firm, that does not excuse them from the requirement to run a tighter administrative organization at lower overhead and salary costs, nor should it be a guarantee of ever increasing profits and share price. In fact, with NYS DFS approved rates, UnitedHeathCare (ticker UNH) stock price performance has over the past ten years risen TEN FOLD -- reaching serial historic highs -- having increased at a STRONG MULTIPLE of Dow Jones, NASDAQ and SP 500 index increases, while also paying a 2% dividend. How much more UNH share price appreciation and dividend growth should be guaranteed by NY DFS on the backs of subscribers? Indeed, based on its multiple of market index performance, New York UNH plan subscribers are if anything due rate reductions! 5./ Given our declining claims and usage, it appears that New York Group rate payers' finances are being drained to support a bloated UNH overhead structure as well as fund unrealistic salary, profit, price-earnings ratio, stock price, and dividend increase expectations, which any DFS grant of a rate increase would simply perpetuate into 2020 and beyond. 6./ While my comments address our recent proposal from and experience with Oxford / UNH, when we have over the past ten years shopped the policy via brokers, we have seen LOCKSTEP RATE INCREASES and ANTI-COMPETITIVE BEHAVIOR in the way of parallel rate and policy re-designs/exclusions, which erode any ability whatsoever to negotiate or to moderate exposure to out-of-pocket costs and rate increases granted year-after-year on an industry-wide basis. We have seen this same collusive behavior since early 2000s decade renewals, and evidence of the collusion has been well reported. No help from US DOJ, who hasn't seen a recent merger proposal it didn't like, and thus I would expect further healthcare industry consolidation, which will served to further erode bargaining power and cost-effective healthcare insurance options. 7./ Reviewing NY DFS’ Summary of 2020 Rate Increase Requests, UNH makes THE HIGHEST DEMANDS, across both Individual and Small Group policy types, with some of the same parallel thinking and collusive behavior that has marked prior rate requests. This sort of demand and behavior simply cannot and should not be endorsed or approved by NYS DFS. 8./ Runaway health care insurance policy premium rate inflation -- far in excess of utilization, as evidenced by the trend in retained earnings and record UNH stock prices -- must be arrested. For the benefit of all New York small and larger businesses affected by these proposed premium rates, DFS can and MUST take steps to impose an Oxford, indeed and industry-wide, rate freeze, if not a reduction, NOW. Should you have any questions you would like to address to me about our experience with group coverages and rates, please to not hesitate

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to call. Thank you for your consideration. -

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They are saying they want to raise our premium 24.4%. It's an exorbitant cost increase, and for what reason? They aren't justified raising it this much. This is an unnecessary burden on everyone on this group.

Regarding plans: Oxford VB2727, CSP21, PPO Platinum, 85629NY0050026 (proposed 15.5% increase) Oxford VB2727, CSP19, EPO Silver, 85629NY0010439 (proposed 13.2% increase) Oxford EPO Silver, 85629NY0010479 (proposed 21.1% increase) My business partner and I currently use the above referenced plans for ourselves and our employees. We received a letter from Oxford notifying us of their intent to file an application with you to approve a rate increase for 2020. This is absurd. Our out-of-network benefits have already been drastically cut from a payout according to usual and customary to 140% of the Medicare fee schedule. Our in and out-of-network deductibles have doubled in the last year and a rate increase has already been applied to our group premium. Pharmacy benefits have been cut and co-pays have been increased. As the VP of a , I can say that the cost of services provided by our clients has not gone up in the last year. It seems like the increase in insurance premiums is not translating to increased pay to medical providers, but rather increased profits for the carriers. Seeing as how costs have not gone up and benefits have been cut, I see no justification for this enormous rate increase. Thank you. Regards,

This is the third year in a row that our insurance company has requested a rate increase. I would be okay with that if it were a few percent a year to go up with inflation, cost of living, etc. But these are double digit percentage increases, year over year. We have had to decrease our coverage to keep up with the increase otherwise we would be paying roughly $7200 MORE a year than three ago. It makes it challenging for a small business to stay in business. Please do not grant Oxford such a high rate increase as this behavior should not be condoned year over year. It is making healthcare almost out of reach and at this point it costs more than our mortgage.

I oppose rate increase based on income and rising cost of living that does not support higher insurance premiums. Continuing price increases in prescription medications have already eaten into my yearly income. Those of us with moderate incomes should not be made to bear the burden of multimillion dollar insurance corporations that do not support our healthcare more fully, but continually require us to pay more and more for less and less service.

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As someone who was once the I am appalled by the greediness of the company under UNH and absolutely reject giving them more than what they get today for a very poor coverage. My employees and myself have to fight over every claim. Bureaucratic paper work and poor in network providers!! So, a big no on rate increase.

We received notice that United/Oxford is requesting to increase our premiums by 15.1% in 202. Over a 2 year period we estimate our premiums have risen by 21%. Nationwide, health care costs are rising by approximately 6% per year. Thus, over a 2 year period we would expect an 12% rise. This is simply an unreasonable increase. Likewise we further submit that United Oxford made a combined profit of over 20 Billion USD in 2018. As a small business, these increases have a substantive impact on our operations. Thank you for your time and consideration.

It’s absolutely insane that these insurance companies continue to raise the premiums. It would be one thing to raise the premium by $10 or so but they continue to raise it by over 10% on an already expensive premium. It’s absolutely horrendous our country can’t figure out a solution to not DROWNING its citizens in debt for taking a simple precaution of having healthcare. We are all subject to illnesses, why must we become penniless just to make sure we don’t succumb to illness.

I just received notice that UnitedHealthcare is requesting a 17.6% rate increase. The massive increases in premiums on an annual basis are unsustainable for my business and I will be forced to discontinue care. The reasons for the increase are opaque and vague. As a whose reimbursement from UnitedHealthcare only decreases on an annual basis, the only real justification for the increase is profit for the company and shareholders. You must act to stop this gouging of the public, you are the last line of defense in this matter.

The requested premium increase of 14.7% is beyond unacceptable. Currently, my premiums are $2,006.74 p/ month for a family of 3 and this increase will result in an additional $280 p/month. Currently, we already have an enormous deductible of $6k for the family, and an annual $13,700 out of pocket expenses coverage. To add to this our co-pays are $75 p/visit. The coverage we receive for the monthly premiums is poor to begin with and this will only compound our expenses. Additionally, I have no other affordable options vs. services unless we go with an HMO which is even worse. A rate increase of 4% to 6% would be more in line with the coverage that is provided by Oxford.

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The requested premium increase of 15.7% is beyond unacceptable. Currently, for our employee (single no family) the premiums are $655.30 p/ month for a single individual and this increase will result in an additional $98 p/month. Currently, we already have an enormous deductible and an annual pocket expenses coverage. To add to this his co-pays are $75 p/visit. The coverage he receives for the monthly premiums is poor to begin with and this will only compound our expenses. Additionally, I have no other affordable options vs. services unless we go with an HMO which is even worse. A rate increase of 4% to 6% would be more in line with the coverage that is provided by Oxford.

Healthcare is in a really unhealthy place. Every year I get a letter in the mail saying that my insurance company is requesting a double digit increase and it seems like every year they get it. My salary has not gone up by double digits. My company's profits has not gone up by double digits so how in the world is anyone supposed to afford this To make matters worse, every year the rates go up and the benefits go down. I am no longer able to afford the medical care I need and I have insurance which is not cheap which basically covers almost nothing above the minimum Every time I need anything beyond the most basic of care, the copay is becoming cost prohibitive and that is even when staying in network. In addition, my doctor wants me to get a certain procedure. This procedure is very basic, happens all the time and is needed to help figure out the source of some of my symptoms. I had everything scheduled but had to cancel because when they contacted the insurance company they said that based on my benefits they were not going to cover anything for the procedure. The procedure was therefore going to cost me $2,000 out of pocket. Who can afford that??? I was then informed that for any kind of procedure the most they would be covering is 70% no matter where I would go. There are some procedures that cost in the 100s of thousands of dollars. Who can afford to cover 30% of those procedures if they are ever needed (hopefully I should never find out)? At this point I have decided to live with the symptoms rather than try to find a solution since I can't afford the journey of trying to find the solution I am generally relatively healthy and I would guess that United Healthcare / Oxford covers around $250-$500 a year for me. The cost of my premiums is over $10,000 and at this point I don't feel like I can afford any kind of medical care except for the very basics while at the same time the insurance company is making more than $9,000 a year in profits off of me. Something needs to be done but what does NOT need to be done is any kind of increase in premiums. If anything, the premiums should be reduced based on the benefits distributed by the insurance company The fact that they are asking for a 26.3% increase is obscene. If I were to perform as badly at my job I would be fired and not be given a 26.3% raise. Please do NOT approve it

You have got to be kidding me with the rate increase. I am a single parent with a child who has My deductible is ridiculous and so are my copays. Because of this I put my child first, of course, taking him

to the doctor regularly and only in an emergency for me. You raise the rates yet provide no additional benefits or services except to pocket the corrupt. It will come to the point where no one will be able to afford your insurance. What a joke. I will tell you that if there is an increase I will no longer be a part of your terrible, corrupt, crappy, insurance company. It is a mortgage payment. I would rather pay for my house than pay your rates.

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There is no reason to raise the rates for those of us with insurance. They say it is because costs keep rising, but they have had continued rising growth and profit for several years now. Clearly that is because they continue to push more of the burden of cost onto their customers. And when people can afford to have insurance but not use it because even with it the costs are prohibitive, they profit even more.

I have just received an announcement from United Oxford that it requested DFS approval for a 17.2% increase to our health insurance premium. This increase is unfair and exorbitant. Our premiums were already high. The attempt by Oxford to justify such a large increase by pointing to a recent event which I can neither corroborate or control ignores the fact that the premium they impose on us today is already too high and provides them with more than enough profit to weather any purported increase in their cost of conducting business. The fee increase proposed will be unacceptable and disruptive on our employees' families who now have existing doctor relationships that will be severed if we are forced to procure health coverage through another insurance company that will not support the same medical community on which we now depend. Please deny the requested increase and cause Oxford to maintain our premium in the same amount. Thank you.

stop it. insurance are for profit companies, and claiming that they need to increase their rates is utter nonsense. They continually increase their rates while decreasing services, and it is out of control. people can no longer afford this! All the while they keep making a profit- and they absolutely make a profit off the backs of the consumer, off the backs of the doctors (who gave up many years of their life for their education and who can no longer truly treat a patient)...its time our government stop governing for them and start representing their constituents. TELL THEM NO.

Every year the rates go up, however, my salary has NOT been increased in over 5 years. I cannot afford to pay increases that a big company is requesting when their tax bills compared to mine are non-existent due to the President assistance to corporation his and others. I vehemently opposed any additional increases. My co-payments are $40 (down from $50) and my deductible is $1,000.00. I have no one who helps me with any of my bills and I'm scared of not being able to afford anything since my rent increases like EVERYTHING ELSE except my salary. Of course, I am looking into other options to increase my salary, but as everyone is aware, working for someone else is NEVER going to make you rich. I cannot afford an increase. I couldn't afford it last year or the year before or the year before when Oxford asked and received their increase.

Over 10 years I paid hundreds of thousands for the health insurance to Oxford for myself and my employees and never needed any benefits. Now, that I am months pregnant, they propose to increase rates by 17%. It is outrageous. Please do not allow the rate increase. Thanks a lot!

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I am writing to strongly oppose Oxford's proposed rate increase of 25.8% for 2020. This will be a tremendous financial burden on our small company, and will make health insurance too cost- prohibitive to be able to offer to our employees. This proposed percentage increase is so large (a shock and awe number) that if and when it is knocked down to 10-15%, it will be deemed as a reasonable increase. I consider this a deceitful tactic. We are already suffering from the 2019 increase, and are forced to re-evaluate whether we can continue to offer coverage to our employees. I urge you to deny this proposed percentage increase, and moreso, accept only a truly reasonable increase proposal --nowhere in the neighborhood of 10% plus. The health insurance industry is taking unfair advantage of their customers and it needs to be curbed.

I was absolutely shocked to get a letter from Oxford Health Insurance saying that they were applying for a 21.4% increase in premiums. As the CFO of a small nonprofit the estimated cost increase for us would be more than $35,000 next year. That amount represents 30-50% of our net income in any given year and is the cost of an entry-level assistant teacher. We will probably have to pass on some of this premium cost to our employees and also to our working families. And all this for a hyper-restrictive Oxford “metro” network that has caused many of us to leave long-time medical providers and pay hundreds of dollars a year for “premium” prescriptions. Please deny this request.

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[NOTE: Also sent via DFW Portal]

June 21, 2019

In re: Oxford/UnitedHealthCare Proposed 2020 Premium Rate Increase

EPO Platinum, 85629NY0010336

To whom it may concern:

I write as the negotiator, buyer and plan administrator for, as well as family member of a covered individual in, my firm's Oxford / UnitedHealthCare Group Health Care EPO insurance policy.

I have written each year since 2011to protest what were in each caseegregiousproposedpremium rate increases in Oxford Health Insurance Group EPO Plan rates. This year, UNH's 16.6% demand is among the most egregious, my response to and contextual comments on which follow.

On June 18, 2019, we received notification dated June 5, 2019 of a proposed 16.62% increase for 2020 group premium rates.

This 16.6% rate of increase is -- once again -- unwarranted, unconscionable and increasingly unaffordable, despite the coverages being more restricted and out-of-pocket costs trending unfavorably for the covered individuals.

I am outraged and adamantly opposed to United Health Care / Oxford proposed 16.6% premium rate increases for 2020 Group EPO Plan policies and am similarly opposed to any further grant of rate increases to Oxford / United Health Care -- PERIOD -- for the reasons I will specify following.

1./ The proposed premium rate increase represents the latest in NINE CONSECUTIVE mid to high DOUBLE-DIGIT (11-24%) per annum rate increases in nine years. Since 2008, our current New York Group rates -- for increasingly limited plan designs of declining actual value with significantly higher medical and pharmacy co-payments -- have cumulatively exceeded a 155% increase in premium rates (an 11.0% cumulative p.a. rate) -- for ever-more restrictive plans -- which Oxford proposes to increase by a further 16.6% this year.2./ All the while, UNH's stock price has soared -- thanks to increases already granted by NYS DFS.

3./ Speaking for my group, usage, claims and plan utilization have DECREASED sequentially for this same period ? opposite to the rate increased granted over this period. It is also my understanding that reimbursement to service providers and physicians has decreased, despite increases in subscriber rates, and increasingly delayed and subject to higher physicians' administrative costs to recover.

4./ While Oxford / UnitedHealthCare is a for-profit firm, that does not excuse them from the requirement to run a tighter administrative organization at lower overhead and salary costs, nor should it be a guarantee of ever increasing

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profits and share price. In fact, with NYS DFS approved rates, UnitedHeathCare (ticker "UNH") stock price performance has over the past ten years risen TEN FOLD -- reaching serial historic highs -- having increased at a STRONG MULTIPLE of Dow Jones, NASDAQ and S&P 500 index increases, while also paying a 2% dividend.

How much more UNH share price appreciation and dividend growth should be guaranteed by NY DFS on the backs of subscribers?

Indeed, based on its multiple of market index performance, New York UNH plan subscribers are if anything due rate reductions!

5./ Given our declining claims and usage, it appears that New York Group rate payers' finances are being drained to support a bloated UNH overhead structure as well as fund unrealistic salary, profit, price-earnings ratio, stock price, and dividend increase expectations, which any DFS grant of a rate increase would simply perpetuate into 2020 and beyond.

6./ While my comments address our recent proposal from and experience with Oxford / UNH, when we have over the past ten years shopped the policy via brokers, we have seen LOCKSTEP RATE INCREASES and ANTI-COMPETITIVE BEHAVIOR in the way of parallel rate and policy re-designs/exclusions, which erode any ability whatsoever to negotiate or to moderate exposure to out-of-pocket costs and rate increases granted year-after-year on an industry-wide basis. We have seen this same collusive behavior since early 2000s decade renewals, and evidence of the collusion has been well reported. No help from US DOJ, who hasn't seen a recent merger proposal it didn't like, and thus I would expect further healthcare industry consolidation, which will served to further erode bargaining power and cost-effective healthcare insurance options.7./ Reviewing NY DFS? Summary of 2020 Rate Increase Requests, UNH makes THE HIGHEST DEMANDS, across both Individual and Small Group policy types, with some of the same "parallel thinking" and collusive behavior that has marked prior rate requests. This sort of demand and behavior simply cannot and should not be endorsed or approved by NYS DFS.

8./ Runaway health care insurance policy premium rate inflation -- far in excess of utilization, as evidenced by the trend in retained earnings and record UNH stock prices -- must be arrested. For the benefit of all New York small and larger businesses affected by these proposed premium rates, DFS can and MUST take steps to impose an Oxford, indeed and industry-wide, rate freeze, if not a reduction, NOW.

Should you have any questions you would like to address to me about our experience with group coverages and rates, please to not hesitate to call.

Thank you for your consideration.

-

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ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails.

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[NOTE: Also sent via DFW Portal]

June 21, 2019

In re: Oxford/UnitedHealthCare Proposed 2020 Premium Rate Increase

EPO Platinum, 85629NY0010336

To whom it may concern:

I write as the negotiator, buyer and plan administrator for, as well as family member of a covered individual in, my firm's Oxford / UnitedHealthCare Group Health Care EPO insurance policy.

I have written each year since 2011to protest what were in each caseegregiousproposedpremium rate increases in Oxford Health Insurance Group EPO Plan rates. This year, UNH's 16.6% demand is among the most egregious, my response to and contextual comments on which follow.

On June 18, 2019, we received notification dated June 5, 2019 of a proposed 16.62% increase for 2020 group premium rates.

This 16.6% rate of increase is -- once again -- unwarranted, unconscionable and increasingly unaffordable, despite the coverages being more restricted and out-of-pocket costs trending unfavorably for the covered individuals.

I am outraged and adamantly opposed to United Health Care / Oxford proposed 16.6% premium rate increases for 2020 Group EPO Plan policies and am similarly opposed to any further grant of rate increases to Oxford / United Health Care -- PERIOD -- for the reasons I will specify following.

1./ The proposed premium rate increase represents the latest in NINE CONSECUTIVE mid to high DOUBLE-DIGIT (11-24%) per annum rate increases in nine years. Since 2008, our current New York Group rates -- for increasingly limited plan designs of declining actual value with significantly higher medical and pharmacy co-payments -- have cumulatively exceeded a 155% increase in premium rates (an 11.0% cumulative p.a. rate) -- for ever-more restrictive plans -- which Oxford proposes to increase by a further 16.6% this year.2./ All the while, UNH's stock price has soared -- thanks to increases already granted by NYS DFS.

3./ Speaking for my group, usage, claims and plan utilization have DECREASED sequentially for this same period ? opposite to the rate increased granted over this period. It is also my understanding that reimbursement to service providers and physicians has decreased, despite increases in subscriber rates, and increasingly delayed and subject to higher physicians' administrative costs to recover.

4./ While Oxford / UnitedHealthCare is a for-profit firm, that does not excuse them from the requirement to run a tighter administrative organization at lower overhead and salary costs, nor should it be a guarantee of ever increasing

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

profits and share price. In fact, with NYS DFS approved rates, UnitedHeathCare (ticker "UNH") stock price performance has over the past ten years risen TEN FOLD -- reaching serial historic highs -- having increased at a STRONG MULTIPLE of Dow Jones, NASDAQ and S&P 500 index increases, while also paying a 2% dividend.

How much more UNH share price appreciation and dividend growth should be guaranteed by NY DFS on the backs of subscribers?

Indeed, based on its multiple of market index performance, New York UNH plan subscribers are if anything due rate reductions!

5./ Given our declining claims and usage, it appears that New York Group rate payers' finances are being drained to support a bloated UNH overhead structure as well as fund unrealistic salary, profit, price-earnings ratio, stock price, and dividend increase expectations, which any DFS grant of a rate increase would simply perpetuate into 2020 and beyond.

6./ While my comments address our recent proposal from and experience with Oxford / UNH, when we have over the past ten years shopped the policy via brokers, we have seen LOCKSTEP RATE INCREASES and ANTI-COMPETITIVE BEHAVIOR in the way of parallel rate and policy re-designs/exclusions, which erode any ability whatsoever to negotiate or to moderate exposure to out-of-pocket costs and rate increases granted year-after-year on an industry-wide basis. We have seen this same collusive behavior since early 2000s decade renewals, and evidence of the collusion has been well reported. No help from US DOJ, who hasn't seen a recent merger proposal it didn't like, and thus I would expect further healthcare industry consolidation, which will served to further erode bargaining power and cost-effective healthcare insurance options.7./ Reviewing NY DFS? Summary of 2020 Rate Increase Requests, UNH makes THE HIGHEST DEMANDS, across both Individual and Small Group policy types, with some of the same "parallel thinking" and collusive behavior that has marked prior rate requests. This sort of demand and behavior simply cannot and should not be endorsed or approved by NYS DFS.

8./ Runaway health care insurance policy premium rate inflation -- far in excess of utilization, as evidenced by the trend in retained earnings and record UNH stock prices -- must be arrested. For the benefit of all New York small and larger businesses affected by these proposed premium rates, DFS can and MUST take steps to impose an Oxford, indeed and industry-wide, rate freeze, if not a reduction, NOW.

Should you have any questions you would like to address to me about our experience with group coverages and rates, please to not hesitate to call.

Thank you for your consideration.

-

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My premiums have increased so much in the last several years as to render my insurance essentially meaningless. On top of that, my deductibles are through the roof - I paid more than $7500 in deductible and out of pocket expenses last year The insurance is meaningless because if I'm paying thousands and thousands of dollars for coverage, I MAY AS WELL NOT BE INSURED. The explanation provided by UH/Oxford for the increase, Rising medical expenses is astounding in its hypocrisy - MEDICAL COSTS ARE RISING BECAUSE OF INSURANCE COMPANIES, LIKE THIS ONE. This is infuriating and I hope NYS DFS takes a stand against further increases like this one.

To whom it may concern; I disapprove of any increase on my insurance premiums. There are no benefits that come from this increase. Please forward this to the appropriate person to handle it. Thank you

I have been notified of a substantial premium increase request by Oxford in the amount of 17.2% and I would like to voice my absolute objection to this rate increase. How much is enough and when will the increases end? $240 dollars is a lot of money for a small, family owned business like mine. higher rates, higher deductibles, higher co-pays...When will this nightmare end? Is anyone in Albany protecting the people of this state from these outrageous insurance premiums? Please do not allow ANOTHER rate increase. This is beyond the rate of inflation, beyond everything that is reasonable. Thank you

The proposed increase of 16.2% is absolutely absurd and untenable for my small business. The cost of our insurance is already astronomical - I pay $2823.19 per month for myself and my young children, and none of us have any conditions that require specialized treatment - just routine checkups and the like. If the cost went up by the proposed rate of 16.2% my monthly cost would be $3,274.90 or $39,298.80 per year. The health insurance system is totally broken, and I am sick of being on the hook to pay for it.

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I don't understand how I have been in this plan for under a year, am an individual already paying $167+ a month, and now have an additional 13% increase?!? I find this to be disgraceful as I see individuals who make a lot more money, pay a lot less or nothing for their health insurance. Or at lease are offered a plan that is covered.

Our current oxford policy as a small group has constantly gone up. We do not even have adequate coverage when we go see a doctor and always end up owing huge fees to see the doctors and for prescriptions. Our copay even for a pcp is 75.00. Now it seems they are suggesting a 13% increase. we cannot afford this and think its extremely unfair based on the high amounts we pay now. Please help us!

I strongly oppose yet again a ridiculously exorbitant increase in the Premium rates for UnitedHealthCare customers. How can NYS approve a 12.7% increase when almost no-one sees that kind of increase in their income, including state employees. It would be completely irresponsible for anyone in NYS government to approve another increase of this magnitude. Thank you for your attention to this.

At the present rate this policy already costs 5X the original premiums. They are requesting a 17.4% increase, which is many times the inflation rate. we are a small trying to do the right thing for our employees. We cannot aford more!!! Please!

This proposed 25% premium rate increase should be illegal. My employer has already had to switch me to a plan that covers less and puts more of the financial burden on me, the employee -- this type of increase will mean my employer will no longer be able to offer coverage at all. Blaming the ACA for this increase is a specious argument, at best. Insteadof jacking up premiums on small businesses, how about talking to the pharmaceutical industry about not charging extortionate prices for drugs? Or the doctors who constantly order unnecessary tests?

I am writing to express my extreme disapproval of my group's proposed premium change of +16.9%. I kindly request that DFS modify this to be more in line with the core inflation rate. Thank you.

A premium increase should not be increased, as health care has become increasingly more expensive and will put basic human healthcare out of reach for so many.

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I am strongly opposed to the rate increases! My company currently pays almost $3900. per month for it's PPO plan. I am diagnosed with and I am not able to work full time as a result of my condition. I have had surgeries over the last five years as a result of my condition. I am a small business owner. The proposed rate increase is not fair or justified.

I am strongly opposed to the rate increases! My company currently pays almost $3900. per month for it's PPO plan. I am diagnosed with and I am not able to work full time as a result of my condition. I have had surgeries over the last five years as a result of my condition. I am a small business owner. The proposed rate increase is not fair or justified.

I am writing on account of Oxford's request to increase premiums by 14.4%. I find this a very hard proposal to support. I do not believe that their expenses have risen by this amount. And I find it very hard to see how consumers can afford large annual increases like this. Our employees are not assured of 14% increases on an annual or even bi-annual basis. Oxford's increase in effect would eat into our employees paychecks in a way that frankly seems inappropriate. I hope the DFS will carefully review their submissions because an increase of this sort is a big number for consumers to swallow. Thank you.

Rates have increased by double digits every year over the last 10 years. Efforts to manage premium expenses have been made by taking high deductible plans and managing health risks internally. Continued increases in premiums makes it difficult to continue to have this insurance. Please consider the high costs of these premiums on the effects of the solvency of small business. Thank you.

The proposed rate increase of 16% is far too high. It should be in line with inflation, at most. We trust that this 'request'is just a negotiating strategy and the the Department will take appropriate action and only approve a reasonable, far lower, rate increase ... or none.

An 18.2% increase, are you kidding me?! My business partner and I created a small business this year. We currently pay Oxford $3,520.83 a month in premiums for This is already very expensive, and it's our largest monthly expense. An 18.2% increase in our monthly premium equals $640.79! On top of the $3,520.83 we already pay! If anything, maybe Oxford needs to change its executive management, find someone competent who can better plan for cost adjustments instead of trying to foist such a ridiculous price increase on its customers who need medical care. By the way, David Wichman, the CEO of UnitedHealthcare, which owns Oxford, makes $18,107,356 a year.

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Oxford Health Insurance, Inc.Small Group2020 Public Comments

received notice that our health insurance provider, Oxford Health Insurance is filing a request with DFS, for approval on a 16% group premium rate increase for 2020. The explanation cites the Federal Risk Adjustment. However a 16% increase for a small, non-profit business like ours is entirely out of proportion, and seemingly an excessive increase. The letter accounted for little more than 8.2% rising health care costs. We'd like additional information with itemized detail explaining the 16% increase. While it remains extremely important to our organization to provide health care to our employees, it's equally important our costs are sustainable. This increase makes it very hard. We would have to potentially consider other more affordable options. We look forward to a response. Thank you.

Premiums don't need to go up in order to keep up with with medical costs. Executives making the decision to do this are already making millions and are only interested in protecting their personal profit and making it increase. a 16.5% increase is RIDICULOUS. There's no need. Insurance is already expensive and don't cover all our needs. We also pay out of pocket for our medical expenses so it's not like we don't cover any of the rising medical costs. Premiums should not go up.

I received a letter from United Healthcare that my group’s premium may increase by 17.6% next year. This is much too great of an increase. I’m due to give birth in A 17.6% increase in the health care premium for me and a dependent is far more than what I have budgeted for health insurance. If an increase in premium is necessary, it should be a reasonable amount that is more congruent with annual inflation. I am requesting that a 17.6% increase not be approved.

To Whom it May Concern, I am writing to protest the increase in the increase in my health plan cost which I was notified this year was planned to increase from the previous year at 17.7%. This health care plan has been increasing significantly each year since I began employment with and is now almost double what it started. This is unaffordable, especially considering there have also been increases in co-pay costs for both PCP, specialist and deductibles for things like hospital visits. This increase in monthly cost while reducing access to healthcare through increasing the prices to actually use it only serves to reduce my access to health care. It is not fair to allow private health insurance companies to continually increase health insurance prices while decreasing the services they provide. Please see below the history of my healthcare costs. United Health Care Oxford HMO Health Plan Cost Year Rate Increase from previous year 2014 $664.83 2015 $721.00 8.45% 2016 $755.55 4.79% 2017 $804.49 6.48% 2018 $862.45 7.20% 2019 $1,015.00 17.69% Sincerely,

My comment is: I IMPLORE you to stop the insanity and deny United Healthcare/Oxford's request for a 15% INCREASE. They just keep getting more money and we get higher costs and higher claim rejections. Enough is enough. Thank you in advance for protecting the residents of NY from the greed of this corporate behemoth.

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I disagree with the proposed increased, being that it will be very expensive.

Dear Superintendent Lacewell, I am writing to file an objection on the proposed premium rate increase of 17.9% recently filed by Oxford Health Insurance, Inc. (OHI). I have the (Freedom) plan, which is small group coverage through my employer, and our HIOS Plan ID number is 85629NY0010246. I have been a customer for years and have had and paid for health insurance coverage all my life, including many years through United Healthcare companies. I very much need health insurance because I'm a human being who gets sick occasionally and who does not want to have to live a life filled with the stress and anxiety of going into serious debt or losing my home if I have an accident or get sick as human beings tend to do. This proposed rate increase will be a major hardship for me as it would be for pretty much every single person I know. My own salary will most certainly not increase by 20% next year to allow me to cover paying out this outrageous rate change, just as it did not increase 10% this year to allow me to cover the 10% increase to the health insurance premiums that I've had to absorb for 2019. Three is no possible way that the actual costs of doing business have gone up by 30% in two years, and I fully believe that this rate increase will only be used to line the pockets of the already disgustingly wealthy executives at the insurance company and will not actually go to paying claims or helping people stay healthy. I am certain that my carrier’s profits, administration, and executive compensations costs are too great and urge you to require it to invest more premium dollars into its customer’s health expenses. I strongly support the Department of Financial Services’ efforts to make more insurance more affordable and information about rate increases more accessible. Actually, I'm literally begging the Department of Financial Services to please, please, please, make healthcare accessible and affordable for regular hardworking human beings like myself - citizens who read real news and who vote in every single election right down to the school board budget in May - but also just for everyone because no one should have to worry about paying outrageous bills when they're sick. Healthcare is a right, not a privilege for the wealthy. Thank you for your attention to this matter. If you need more information about my situation, please feel free to contact me at:

An 18.3% rate increase is an outrage. We are mandated by NYS to provide Health Insurance to our full-time employees. We work within small margins. Any additional amounts would compromise our ability to conduct business and even have employees. If that is the case, then no insurance would be offered and Oxford would receive no premiums at all. It is not our small company's fault that Oxford's number of services has increased and that their risk adjustment amount will be lowered in 2020. Our increased premiums cannot make up the difference. They need to ask themselves who their services are truly benefitting- the consumer or their greed. This is an ongoing crisis regarding Health Care reform and it must be fixed in favor of the consumer.

The requested 18.2% premium increase for the year 2020 is outrageous! That is almost 20%!!! from one year to the next. I can't pass along that type of cost to my customers. I ask that the state deny this premium increase request.

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Proposed rate increase of 16.2% is outrageously high! is a small group of 2 people (myself and one employee). In 2018, I paid $22,545 in insurance premiums, plus $10,000 as a contribution to my employee's health insurance premium, PLUS $25,620 for out-of-pocket medical expenses (i.e., expenses not paid by insurance). All this represents over 25% of my income. You would think that for this level of expense I must have been unbelievably sick, but no, I had no major illnesses, hospitalizations, surgeries, etc. This was just routine health care! I would also comment that when you add this to the triple tax regime that I am subject to in NYC, I often wonder whether it isn't time to move the entire business out of this location. As just explained, I am vehemently opposed to the proposed rate increase of 16%.

I received a Notice of Proposed Premium Rate Change, showing an increase of 15.4%. I object! No! You should not raise the premiums. 15.4%?! No way! Premiums are already too high. My family makes less than per year. I often have to choose if it is worth paying the copays premiums to see my doctors. This should not be such a struggle! STOP RAISING PREMIUMS!!! I understand this raise is due to “rising medical expenses,” but Oxford, you are making enough money!! People need affordable health care! ENOUGH!!

This proposed increase of 15.4% is unacceptable. It makes me scared to think that I might not be able to maintain a base level of health care. What the hell is going on in this country? Health care should provide a foundation of health and wellness to our society, but instead it brings constant overtones of stress, fear, and anger. My family’s income is below and this increase will significantly affect our budget for other basic needs. This kind of dramatic rate increase to be paid by consumers / patients is absurd. Why doesn’t your CEO take a 15.4% salary cut? I’m sure he can afford it. Get your act together and treat your customers fairly!

I write to file an objection on the proposed premium rate increase of 16.6% recently filed by Oxford Health Insurance, Inc. Our company has been a customer since In the last 4 years we have already seen an increase of more than 25%. This additional proposed rate will mean an 45.9% increase over 5 years and will have a substantial impact on our budgets. I encourage the Department to carefully review our insurance company’s filing. I urge you to ensure that a maximum investment is made in consumer medical claims. I strongly support the Department of Financial Services’s efforts to make more insurance more affordable and information about rate increases more accessible. Thank you for your attention to this matter. If you need more information about our company, please feel free to contact me.

Your rates are already too high—do not raise the premiums! I am pregnant and have been suffering with large medical bills since my first doctors visit. I am unable to provide for my family with these medical bills increasing due to your already high premium rates. DO NOT raise the premiums! Thank you.

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Hello, I work at a non profit as a As it is, the cost of covering health insurance for me and my family is a burden. I ask that this rise in cost not be approved. The impact it would have on my ability to adequately support my family is significant. Surely Oxford can survive without it. Thank you,

Dear Superintendent Lacewell, I write to file an objection on the proposed premium rate increase of 17.9%, recently filed by Oxford Health Insurance, Inc. (OHI). I have the Freedom plan, which is small group coverage through my employer, and our HIOS Plan ID number is 85629NY0010246. I have been a customer for years. I need health insurance because medical care is expensive, and 100% necessary. I use my insurance benefits for routine medical care as well as for care after accidents, including to help cover some of the costs of surgery as a result of a recreational injury my partner sustained this spring. Insurance rate increases have already caused my take home salary to not keep up with inflation. This proposed rate increase will be a major hardship for me. I believe that my carrier’s profits, administration, and executive compensations costs are too great and urge you to require it to invest more premium dollars into customer health expenses. I strongly support the Department of Financial Services’ efforts to make more insurance more affordable and information about rate increases more accessible. Thank you for your attention to this matter. Further, I strongly support efforts to create a single payer medical system in NYS and across the country. If you need more information about my situation, please feel free to contact me at:

Re: Notice of Proposed Premium Rate Change EPOGold, 85629NY0010431 To Whom It May Concern: In response to the letter dated June 5th that we received from UnitedHealthcare/Oxford regarding our proposed premium rate changes, we would like to comment: We are a small, privately-owned business with a total of

employees. Of those employees, we currently have on the medical plan. Our insurance went up 7% for 2019 and you are proposing a 17.9% increase for 2020. We were not able to give raises last year due to the high cost of our premiums and with a proposed 25% increase in 2 years, there is no way a small business can afford this type of medical coverage for employees. Yes, medical and administrative costs are expensive. But how can you justify a 7% increase in 2019 and projected 17.9% increase for 2020 when we can’t even give our employees a 2% raise due to the yearly increases in premiums for our small business? Please tell us what we should do. We took the time to write our comments, we would appreciate your time in responding. We look forward to hearing from you.

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I recently received a notice from United Health Care (OXFORD) regarding their request for rate increase, which I think is absolutely absurd because the service and coverage are poor and they want to increase their premium? This sounds just like NYCMTA same crappy service but the fare keeps on going up with the same lame excuse. I say, let's do medicare for all and /or have socialize medicine like any other developed country such as UK, Japan, Canada, etc. Why do American citizens go to Canada to get cheaper insulin because drug makers are one of the biggest crooks and drug dealers on earth especially in the US. I don't get 15.2% raise from my employer why should health insurance company request for that amount rate increase? Rising of medical cost? In what area, paying CEO $15miilion salary? Seems like that's the only reason/excuse insurance company has. I know make medical for all or socialize medicine/insurance will put insurance companies out of insurance and I am sure they already have lobbists stand in line and ready to bribe politicians to make laws in their own favors. The US is the only country on earth people declare bankruptcy because of high medical expenses. Not that insurance companies or politicians give a because politicians got some of the best coverages and they cheat steal and lies. The US is FOR PROFIT nation and has nothing to do for the well being of ordinary citizens. I'm only getting 2% raise but why should insurance companies get 15.2% rate increase and you wonder why people can't afford decent medical care in the US not that insurance companies care. I strongly recommend that the NYS decline the request of rate increase by the insurance companies or only give them 2% rate increase. Like I said, I'm only getting 2% raise why should the insurance company get 15.2% raise? To give more bribery to politicians?

The New York State Department of Financial Services should not approve the requested exorbitant premium rate increase of 17.9% by United Healthcare (underwritten by Oxford Health Insurance, Inc.) on the health insurance policy referred to above. The reasons provided by the insurer in its Notice of Proposed Premium Rate Change, dated June 7, 2019, are unacceptably ambiguous: rising medical expenses for which they state a number of factors contribute, including increases in the cost of medical services and increases in the amount of services used. They provide no evidence that the cost of medical services, or the amount of services used, has gone up by anywhere near 17.9% in one year. I have read the more detailed narrative summary provided by Oxford Health Insurance, Inc., on the DFS website. There is, in fact, no narrative provided there at all, just a table which lists annual claim trend rates; expense ratios; andpre tax profit ratios. There is no support provided for these numbers, nor any narrative explanation of why those numbers support or justify the insurer hiking up its premium by 17.9% (or any percent, for that matter) from one year to the next. It is clear that the explanation the insurer states that they have provided is no explanation at all, and should therefore be rejected out of hand. Furthermore, given the historical abuses and notorious waste by the health insurance industry and insurers in particular, the state should be wary of approving such an extreme price hike, which hurts consumers and the general public. Sincerely,

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Re: Oxford Health Insurance Proposed Premium increase for 2020 I respectfully submit this letter to strongly oppose the proposed premium increase in 2020 that United HealthCare is filing with the New York State Department of Financial Services. The 15% increase to a small business company like ours is too high and way out of line with any normal increases. We are acutely aware of how broken the medical system is in this country and despite years of legislative conversations and lawmakers trying to address the problematic issues, there have been little progress. Medical providers such as United HealthCare always cite the rising medical costs as the reason for increasing premiums. This rate change is being passed onto the consumers, businesses year after year at double digit percentage. For a small business like ours, it is unsustainable! We are a small production company with only 1-2 employees. This problem is systematic and pervasive in this country and need to be addressed by all medical insurance providers. I urge you not to go along with United HealthCare's proposal and approve the premium rate increase, but instead urge them to work to provide a reasonable rate for all insured consumers. Sincerely,

I believe I am being singled out in my premium increase because of the high nature of my bills this calendar year, which I don't believe will be the same next year, and I would like to plead to NYS to not burden me with a 17.4% premium increase as Oxford Health Insurance, Inc. is requesting.

Our small nonprofit -- which is dedicated to the educational, social, and emotional needs of children and to creating a just, compassionate, and restorative world for all -- places a high priority on the health and welfare of our employees, who work so hard on others' behalf. Our already-high Oxford EPO Gold health insurance premiums, which have increased significantly over the years, place an undue financial burden on both our organization and our employees, and we strongly oppose the further rate increase requested by Oxford Health Insurance (OHI). For the sake of the many organizations and individuals laboring tirelessly to leave this world a better place than they found it for relatively littlecompensation, please deny this unwarranted and excessive premium rate increase.

I received notice that Oxford wants to raise premiums by 13%. That is outrageous. The premiums are already over $800 monthly, so this will raise it to more than $900 for a plan with limited benefits, high deductibles and very high copayments. I urge you to reject this request by Oxford.

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