Consumers Union’s comments on Anthem Blue Cross’s proposed rate increase for individual health insurance in California for the 2017 plan year. In particular, Consumers Union calls attention to:
  1. Unusually high medical trend projections, particularly in terms of prescription drugs, without supporting data to prove that projection or explanation of what they are doing to respond to that trend.
  2. Failure to explain quality improvement or cost containment efforts.
  3. Factors that were not adequately supported, and an actuarial certification that relied on limited information in certifying the filing.