Instructions for Commenting to HHS on a Specific ACA Health Insurance Plan’s Rate Increase of More Than 10%

If you really want to get in the weeds and comment on a SPECIFIC PLAN with a proposed increase of 10% or more, do the following:

•  Go to

•  Select “Search ACA-Compliant Products.”

•  Select Missouri and click on “Submit Search.”

•  The search will return a list of insurance plans in the state with proposed rate increases of 10% or greater.  Click on a plan to see the details about the rate hike.


•  After clicking on a plan and reading through the company’s reasons for raising the rates on that particular plan you may want to refer to CCM’s reasons for asking that the company’s rate increases be found excessive.

Blue Cross Kansas City Rate Filing HIOS Issue ID #34762 1-1-16

Coventry (St. Louis) Rate Filing HIOS Issue ID #44527 1-1-16

Coventry (Kansas City) Rate Filing HIOS Issue ID #44240 1-1-16

Cox Rate Filing HIOS Issue ID #96384 1-1-16

Humana Rate Filing HIOS Issue ID #30613 1-1-16

United Rate Filing HIOS Issue ID #14162 1-1-16

•  At the bottom of the page you will find a section called “Consumer Comments” that provides the instructions for submitting comments.

•  Click on, which will auto-populate an email with the appropriate subject line.

•  Write your comments, sign your name and address, and send.

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CCM Asks Feds to Hold Hearing, Find Health Insurance Rate Hikes Excessive

St. Louis, MO (July 30, 2015) — Consumers Council of Missouri is calling on the U.S. Department of Health and Human Services to investigate projected rate increases from Coventry Health Insurance and four other Missouri insurers, each of whom has proposed raising rates by more than 10 percent in 2016.

Coventry Health Care, which is owned by Aetna, is one of the major carriers on the federal exchange for Missouri.  It has filed for 2016 rate increases of more than 20 percent.  Four other insurers have proposed 2016 increases exceeding 10 percent, which is the threshold the federal government set for challenges.

Missouri is the only state in the country in which the Department of Insurance has no authority over health insurance rates and in which health insurers do not even file their rates.  As a result, Missouri consumers are dependent on HHS for information regarding health insurance rate increases, and under the requirements of the Affordable Care Act, HHS reviews health insurance rates for Missouri.

HHS made no rate information public regarding rates proposed for 2014 and 2015.  But this year, after CCM filed a Freedom of Information Act lawsuit seeking the Missouri rate filings, HHS has revealed the rates for all states at a new website,

CCM wants YOU to help!

Please comment on the excessive rates

proposed for 2016.

Here’s how:

Look at these documents related to CCM’s comments on unreasonable rates:

•  CCM’s letter to HHS seeking a hearing on 2016 rates filed by Coventry that increase as much as 28.9 percent and deem the rates unreasonable.  We also ask HHS to find unreasonable the rate increases above 10 percent filed by four other carriers.

•  A summary of the reasons rates proposed for Missouri are unreasonable.

•  Background of on the proposed rate increases for Missouri.

Then CLICK HERE to email your comments.

Some pointers:

•  Subject line – Comments on ACA health insurance rates proposed in Missouri for 1-1-2016

•  Ask the Department of Health and Human Services to deem the rates unreasonable because of specific reasons — choose the ones you like best from the summary and background documents available above.

•  Your comments don’t have to be long but they should be substantive.

•  The only rates that can be challenged are those that exceed 10 percent increases.

•  Sign the email with your name and address.

If you want to get into more detail, read the documents below.

More specifically, if you get your health insurance from one of the five insurance companies that has proposed rates in excess of 10 percent, please comment specifically on it.  (If you comment on a specific plan, put the plan description and number in the subject line.)

Click here for Missouri 2016 Rate Overview.

Click on these links to see comments on the following companies’s plans:

Blue Cross Kansas City Rate Filing HIOS Issue ID #34762 1-1-16.

Comments on Kansas City Coventry Rate Filing HIOS Issue ID #44240 1-1-16.

Comments on St. Louis Coventry Rate Filing HIOS Issue ID #44527 1-1-16.

Cox Rate Filing HIOS Issue ID #96384 1-1-16.

Humana Rate Filing HIOS Issue ID #30613 1-1-16.

United Rate Filing HIOS Issue ID #14162 1-1-16.

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Ameren Wants to Raise Your Rates Again!

Take the Opportunity to Tell Regulators How Higher Electric Bills Would Affect Your Budget

Ameren Missouri wants to increase the rates customers pay by nearly 10 percent (9.65 percent) in order to raise its income by $265 million a year.  Since 2008 Ameren customers have suffered under rate increases of more than 43 percent.

The company also wants to raise the profit it can earn to 10.4 percent from the current 9.8 percent.  Consumer advocates want to lower that percentage to 9.1 percent.  Ameren also wants to continue the fuel adjustment charge, which allows it to raise customers’ rates when the price of fuel goes up.  Consumers want to eliminate the fuel adjustment charge.

Submit Written Comments

Public hearings took place In January, but the case continues.  If you were unable to attend a hearing you may submit written comments to the commission.  Click here to go to the comment page on the PSC website.  The case tracking number is ER-2014-0258.

The PSC is not obligated to consider written comments as it does testimony at public hearings, which is given under oath.

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CCM Fights for Consumer Interests During 2015 Legislative Session

Let your legislators know where your opinion on these bills.  To find out who represents you in the House and the Senate, CLICK HERE.

Then email your representative and senator asking them to vote your interests on these bills.


CCM Supports:

Senate Bill 160 — Utility Transparency and Fairness Act — Sen. Dan Brown

The bill would require all regulated utilities to publicly file quarterly earnings reports so that the public will know when a utility is earning more money than regulations authorize.  Some electric utilities already must file such reports — but those reports are currently secret, according to a rule of the Missouri Public Service Commission.

It would also require the Public Service Commission to determine in a general rate case how any rate increase would impact consumers when it sets the allowable rate of return for a utility.

House Bill 83 — Adjustable Due Date for Fixed-Income Customers — Rep. Paul Curtman

This legislation would allow customers who are on a fixed income due to benefit programs such as Social Security to have their utility bills’ due dates adjusted without incurring a late payment charge.

CCM Opposes:

Senate Bill 310 — Public In-Service Accounting (PISA) — Sen. Ed Emery

This bill would radically change the way the Public Service Commission calculates electric rates in a way that tilts the rules even more in favor of the utilities.  It would add significantly higher charges on the monthly bills of customers of Ameren Missouri, KCPL and Empire District Electric Co.

The worst provision in the bill would mandate “construction accounting.”  It has similar features to the pre-payment scheme called Construction Work in Progress (CWIP), which would allow a utility to charge customers for a new energy generator – like a nuclear plant – while it builds that plant and before the plant ever – if ever – produces any energy.  Such charges are banned in Missouri under a law passed by voters in 1976.

Senate Bill 403 – Infrastructure System Replacement Surcharge for Gas Companies — Sen. Mike Kehoe

The bill would allow unlimited increases in the so-called gas ISRS, a surcharge that requires consumers to take more risk for a gas company’s building projects.  It would loosen the Public Service Commissions oversight of monopoly gas companies by allowing up to 11 years before a company’s rates could be reviewed.

Governor Nixon vetoed this bill last year saying, in part, “While there is much in [the bill] to benefit utilities, there is little, if anything, in it for consumers. Nowhere does the bill mandate increased reliability or enhanced safety and nowhere does it offer the real possibility of lower utility bills.”


CCM Supports:

House Bill 820 — Predatory Lending — Rep. Tracy McCreery

The bill will cap the rate on four types of small dollar lending products (payday loans, car title loans, consumer installment loans and small loans) at 36 percent APR (annual percentage rate).  Currently the APR averages 455 percent in Missouri. The current state of predatory lending compels immediate intervention to prevent continued exploitative interest rates that trap people in cycles of debt.

CCM Opposes:

House Bill 256 – Merchandising Practices – Rep. Tony Dugger

Missouri law prohibits fraud in business deals.  When a business commits fraud it can’t be sent to jail the same way an individual can.  Instead it can be held liable by the attorney general of the state or the person it harmed under the Merchandising Practices Act.

This bill would excuse businesses with a track record of shady practices from fraud claims under the Merchandising Practices Act.


CCM Supports:

House Bill 939 — Protections for Ticket Buyers — Rep. Tracy McCreery

The bill requires transparency in online ticketing and puts restrictions on ticket vendors’ practices in selling paperless tickets and reselling tickets to protect the purchaser of such tickets.

To learn more about this issue, CLICK HERE.>>

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Forum to Discuss Health Care Finance Beyond the Affordable Care Act

You Are Invited:

Health Care Finance
Beyond the Affordable Care Act:
Missouri and Single Payer

Thursday, March 6, 2014
6:30 – 8:30 PM
Central Reform Congregation
5020 Waterman Boulevard
St. Louis MO 63108

Despite the ACA’s many vital reforms of the health insurance industry, fundamental problems remain.  Professor Gerald Friedman, Ph.D., will discuss the merits and limits of the ACA, the problems going forward, and how single payer is the only way to control costs and provide affordable coverage for all Americans.  He will present estimates of how a single-payer system could work in Missouri, the savings it would achieve and potential financing methods.

Friedman, Professor of Economics at the University of Massachusetts – Amherst, focuses on economic history, labor history and economics, and the history of economic thought.  He has been a regular media correspondent on the international financial crisis.  Friedman earned his doctorate in economics at Harvard. He is the author of several books and scholarly articles.

RSVP requested but not required.  Email
Light refreshments will be served.
Admission is free but donations are welcome.

Hosted by:
Physicians for a NationalHealth Program
Consumers Council of Missouri
Missouriansfor Single Payer Health Care for All

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Consumers Win With Governor’s Veto

Today, Wednesday, July 10, Governor Jay Nixon vetoed the bill that would have cost consumers hundreds of millions of dollars more in our gas utility bills over the next five years.


Click here to email the Governor to thank him.

Or call him at 573-751-3222.

By vetoing SB 240 Governor Nixon prevented gas utilities from adding more costly surcharges to consumers’ bills.  He also maintained the current balance in the rate process that gives consumers a fighting chance against the gas companies, which enjoy monopoly status and very healthy profits.

To read the Governor’s veto message, click here.

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