Insurer filings suggest COVID-19 pandemic will not drive health spending in 2022

The COVID-19 pandemic disrupted healthcare spending and utilization trends in the United States, though it is not yet clear how long that disruption will last. In April 2020, health spending dropped precipitously as providers cancelled elective care and patients practicing social distancing avoided healthcare facilities. Though it has mostly rebounded, utilization of health services has remained somewhat lower than normal. Whether there will be pent-up demand from delayed or forgone care in the last year remains to be seen. Plateauing vaccination rates and new COVID-19 variants may introduce more uncertainty on future health costs.  

While uncertainty around the pandemic’s effect on health spending remains, health insurance actuaries have access to the latest health utilization and spending data and can use these data to model future trends. Reviewing health insurer premium calculations for the coming year can give us a glimpse into how the pandemic may or may not affect health spending and utilization in the future.  

Healthcare use plummeted early in the pandemic, but has mostly rebounded

In this brief, we review initial 2022 premium rate filings for Marketplace-participating individual market insurers in 13 states and the District of Columbia. Although the ACA individual market represents a small share of the privately insured population, the rate filings for this market are detailed and publicly accessible, making them a useful source of information on how health insurers are thinking about their likely costs for the next year. We also reviewed rate filings for other potential factors that could influence health spending in the next year, such as telemedicine.

We find most of these insurers expect health utilization patterns to return to pre-pandemic levels and therefore most are factoring in no additional costs or savings into their 2022 premiums. We found that these insurers tended to make similar assumptions about how COVID-19 would affect their group market costs.

In initial filings, most Marketplace-participating insurers are assuming COVID-19 will have no effect on their 2022 costs

Of the 75 insurer filings submitted in these states, only 13 say the COVID-19 pandemic will have an upward effect on their costs, with most of those stating that the impact would be less than 1%. This includes seven plans in New York, three plans in Connecticut, one plan in Tennessee, one plan in Michigan, and one plan in Vermont. Three insurer filings said the pandemic would have a downward impact on their costs. About half (37 insurers) say the pandemic will have no net impact on their 2022 costs. The remaining insurers either did not specify a COVID-19 cost impact or redacted it.  

Among the 13 plans that specified cost increases due to COVID, reasons included costs related to ongoing COVID-19 testing, treatment, and vaccinations (8 insurer filings), and anticipated vaccination boosters (7 insurer filings).

Few insurers expect ongoing expenses for COVID-19 testing, treatment, and vaccinations to have a net impact on costs in 2022

Though rates of hospitalizations and deaths due to COVID-19 have dropped sharply in recent months, several insurers anticipate ongoing expenses for COVID-19 testing, vaccination, and treatment, including first-round vaccinations for younger enrollees or those who delayed vaccination. With uncertainties around newer COVID-19 variants, some insurers are anticipating costs for a “booster shot” for individuals in 2022. However, these initial rates were filed before FDA and CDC said COVID-19 booster shots are not necessary for fully vaccinated people at this time.

Though this brief focuses on individual market rate filings, our review of ACA-compliant small group filings found similar projections for the impact of COVID-19 on 2022 costs. Insurers that offer plans in both the individual and small group markets generally projected a similar impact of COVID-19 on rates in each market.

Insurers also considered telehealth use and other policy changes in 2022 initial rate filings

17 of the 75 insurers mentioned telehealth and most anticipate continued use but none expect impact on net costs after the pandemic

The extent to which virtual or phone visits will be used in place of in-person visits or in addition to in-person visits remains uncertain. Among plans that mentioned telehealth in their rate filings, most concluded that its utilization would have neither an upward nor downward net effect on their costs in 2022.

Some insurers projected a decrease in average morbidity of individual market enrollees in 2022 due to subsidy expansions

Some insurers expect the increased federal premium subsidies through the American Rescue Plan Act (ARPA) will increase enrollment in Marketplace plans next year. A handful of insurers projected the increased enrollment due to the ARPA will also lower average morbidity, with healthier individuals newly enrolling in the individual market. These insurers said the ARPA would have a small downward effect on their premiums, of less than 5%.

Few insurers mentioned the No Surprises Act in their 2022 rate filings

The No Surprises Act prohibits most surprise out-of-network billing starting in 2022. Overall across all markets, the CBO estimated private health insurance premiums could decrease by 0.5% to 1%, though the impact of the No Surprises Act could vary from this estimate in the individual market, which has narrower networks than other markets. One insurer, Blue Cross Blue Shield of Vermont (BCBSVT), did not quantify the impact of the No Surprises Act for 2022 individual market rates, but noted that costs of out-of-network services may decrease. However, they also said that some of the services under the No Surprises Act are currently not covered and therefore the cost of covered care may increase.


In the states with available insurer rate filings so far, most Marketplace-participating insurers expect their costs to return to normal and therefore say the COVID-19 pandemic will not be a factor in their 2022 premiums. Insurers are generally expecting utilization to return to pre-pandemic trends, though several say telehealth is here to stay. The American Rescue Plan Act is expected to increase the number of enrollees in the individual market. Some insurers predict these new enrollees may be healthier and lower risk than current members, though many plans did not quantify the impact of new enrollment on costs in 2022.

While insurers utilize comprehensive data to project future changes in healthcare spending and utilization, their projections remain speculative, especially in the context of the pandemic. Uncertainties remain on how new COVID-19 variants, the plateauing uptake of vaccinations, and potential pent-up demand from delayed care might affect costs in the future.


Data were collected from health insurer rate filings submitted to state regulators for Marketplace-participating individual market insurers. Most rate information is available in the SERFF filings (System for Election Rate and Form Filing) that includes a base rate and other factors that build up to an individual rate. This analysis only includes rate filings that were made public on or before July 13, 2021.