Tennessee health insurance marketplace guide 2023

Tennessee has a federally run exchange, so enrollees use HealthCare.gov to sign up for exchange plans.

In December 2012, then-Gov. Bill Haslam announced Tennessee would not develop its own health insurance exchange, citing a lack of information from the federal government.

Prior to his 2012 announcement, Haslam had leaned toward a state-run exchange. He believed local state control was preferable and that the state could run the exchange more cost-effectively that the federal government.

However, Republican legislators opposed the exchange, Tea Party supporters staged repeated protests, and Tennessee eventually ended up with an exchange run by HHS.

For 2023 coverage, six insurers offer exchange plans in Tennessee, including one newcomer:

• Ascension Personalized Care/US Health and Life (new for 2023; plans available in central Tennessee)
• Blue Cross Blue Shield of Tennessee (held the large majority of the state’s individual market share as of 2019)
• Celtic/Ambetter
• Cigna
• Oscar
• United Healthcare

Bright Health, which offered coverage in the Tennessee exchange in 2022, announced that they would exit the individual market nationwide at the end of 2022, so their plans are not available for 2023. But all areas of Tennessee have at least three participating exchange insurers in 2023.

There were six insurers offering coverage in Tennessee’s exchange in 2022, up from just three in 2018. Here’s a summary of how insurer participation in the state’s exchange has changed over the years.

• 2014: When the exchanges launched for 2014, plans were available in Tennessee’s exchange from Blue Cross Blue Shield of Tennessee, Community Health Alliance (an ACA-created CO-OP), Cigna, and Humana, although only BCBSTN offered plans statewide.
• 2015: Time/Assurant joined the Tennessee exchange statewide in 2015, bringing the total number of participating insurers to five.
• 2016: Four insurers offered plans: BCBSTN, Cigna, Humana, and UnitedHealthcare. UnitedHealthcare was new to the exchange for 2016, and according to Kaiser Family Foundation’s analysis, UnitedHeathcare offered at least one of the two lowest-priced silver plans in the exchange in 73 of Tennessee’s 95 counties in 2016. But Assurant and Community Health Alliance both stopped selling plans at the end of 2015. The CO-OP’s demise was due in part to the severe shortfall in federal risk corridor funding, although the CO-OP had stopped selling 2015 plans as of January 15, 2015, noting that they had already met their enrollment goal for the year. Community Health Alliance had planned to begin selling plans again during the 2016 open enrollment, but instead they ceased operations altogether at the end of 2015, leaving 27,000 enrollees who needed to select new coverage for 2016 from a different carrier.
• 2017: Plans were available from Humana, Cigna, and BCBSTN. Like Assurant’s brief stint in the exchange, UnitedHealthcare’s participation was also short-lived, as they exited the entire individual market in Tennessee at the end of 2016. The Department of Commerce and Insurance confirmed that the exit applied to both the exchange (UnitedHealthcare Insurance Company) and off-exchange (UnitedHealthcare Life Insurance Company). The state reported that 40,879 people needed to secure new coverage for 2017 as a result of United’s exit (the large majority of these enrollees had their United coverage through the exchange). 2017 was also the first year that BCBSTN opted not to offer statewide coverage. As of 2017, BCBSTN stopped offering coverage in the metro areas of Knoxville, Nashville, and Memphis, which are the three largest metropolitan areas in the state.
  Blue Cross Blue Shield of Tennessee had the lion’s share of the Tennessee exchange market in 2016, covering almost 69 percent of the enrollees. Because of BCBST’s exit from the three metropolitan areas, approximately 52,000 people in Nashville, 31,000 people in Knoxville, and 29,000 in Memphis had to switch to a different plan for 2017. So although there were three insurers offering plans in Tennessee’s exchange for 2017, residents in 73 of the state’s 95 counties had only one carrier option in the exchange. Cigna offered coverage in the Memphis and Nashville areas; Humana offered coverage in the Memphis, Nashville, and Knoxville areas, and BCBSTN offered coverage in the rest of the state.
• 2018: There was quite a bit of upheaval in the Tennessee exchange for 2018, in terms of insurer participation. Humana stopped offering individual market coverage in any states at the end of 2017. Humana’s exit meant that residents in the Knoxville area were facing the possibility of having no exchange insurers at all in 2018. Humana insured about 40,000 people in the Knoxville area, and about 79,000 people across all three metropolitan areas in the state. State regulators scrambled to reach a solution, and succeeded. In May 2017, Blue Cross Blue Shield of Tennessee agreed to once again offer coverage in 2018 in the Knoxville area in order to ensure that all areas of the state would have insurance plans available in the exchange.
  While it initially appeared that there would only be two insurers in the Tennessee exchange for 2019, Oscar Health’s entry to the market meant that three insurers offered plans:
  • Cigna’s plans were available in a total of 22 counties in Memphis, Nashville, and the Tri-City area (the eight eastern-most counties in the state), just as they were in 2017.
  • BCBS of Tennessee had plans available everywhere except Memphis and Nashville. They continued to offer coverage in the non-metro areas of the state where they offered plans in 2017, and expanded back into the Knoxville area.
  • Oscar Health has plans available in nine counties in the Nashville area.
  • Nashville and the Tri-City areas were the only parts of the state where enrollees had a choice between two insurers, with both BCBSTN and Cigna offering plans in the Tri-City area, and Oscar and Cigna offering plans in the Nashville area.

Tennessee Insurance Commissioner, Julie Mix McPeak, expressed satisfaction that all areas of the state would have at least one insurer offering coverage in the exchange in 2018, but she reiterated how the uncertainty caused by the Trump Administration and Congress was damaging the individual health insurance market, noting that “the uncertainty about the future of the exchange, cost-sharing reduction payments, and enforcement of the individual mandate will likely increase carrier rate requests by 15 to 20 percent above what they would have otherwise filed. I share consumers’ frustrations about federal uncertainty and how that is impacting their ability to afford insurance.”

• 2019: Bright Health joined the Tennessee exchange for 2019, offering coverage in 16 counties in the Knoxville area, nine counties in the Nashville area, and five counties in the Memphis area.
  Celtic (Centene) also joined the Tennessee exchange for 2019, with plans available in Memphis and Chattanooga. Much of the state had multiple carrier options for 2019 coverage:

• • Nashville: Oscar, Cigna, Bright
  • Knoxville: BCBSTN, Bright, and Cigna
  • Memphis: Bright, Oscar, Cigna, and Celtic
  • Tri-City area: BCBSTN and Cigna
  • Chattanooga area: Celtic and BCBSTN
• 2020: Tennessee continues to have five exchange insurers in 2020, but three have larger coverage areas. Blue Cross Blue Shield of Tennessee came back to the Memphis and Nashville areas for 2020. Celtic expanded into the Nashville and Knoxville areas, and Cigna expanded into the Chattanooga and Jackson areas.
• 2021: UnitedHealthcare rejoined the exchange in Tennessee for 2021, after leaving at the end of 2016. UnitedHealthcare’s plans are available in all counties in rating areas 3, 4, 5, 6, and 8 (southern/central and western Tennessee). Including UHC, Tennessee’s exchange had six insurers offering coverage for 2021.
• 2022: All six insurers continued to offer coverage in 2022.
• 2023: Bright Health exited the market at the end of 2022, but Ascension Personalized Care/US Health and Life joined the exchange, keeping the number of participating insurers at six.

Open enrollment for individual/family health coverage in Tennessee runs from November 1 to January 15. Outside of open enrollment, a qualifying event is necessary to enroll or make changes to your coverage.

If you have questions, our comprehensive guide to open enrollment and guide to special enrollment periods can help.

Tennessee has six insurers offering marketplace/exchange plans for 2023, including one new insurer (Ascension/US Health & Life) and one exit (Bright Health). The five existing insurers proposed the following average rate changes, according to the federal rate review site:

• Blue Cross Blue Shield of Tennessee: 6.9% increase
• Cigna: 9.9% increase 
• Oscar: 5.8% increase
• Celtic/Ambetter: 5.8% increase
• UnitedHealthcare: 11.35% increase
• US Health and Life: New for 2023, so no applicable rate change

Bright Health had initially proposed an average rate increase of about 12%, but ended up exiting the market instead. The weighted average rate change for the remaining insurers amounted to an increase of about 8.5%. As is always the case, however, weighted average rate increases don’t tell the whole story:

• They only apply to full-price plans, and most enrollees receive premium subsidies that cover some or all of their premium (90% of the people who enrolled in 2022 coverage through Tennessee’s exchange were receiving premium subsidies). For enrollees with subsidies, net rate changes depend on how their specific plan’s rates are changing, as well as any changes in their premium subsidy amount (which depends on the cost of the benchmark plan, as well as the enrollee’s projected income for the coming year). Fortunately for marketplace enrollees, the Inflation Reduction Act extended the American Rescue Plan’s subsidy enhancements through 2025, keeping coverage more affordable than it was prior to 2021.
• Overall average rate changes don’t account for the fact that premiums increase with age. A person who has unsubsidized individual market coverage for several years will see their rates increase each year — just due to their increasing age — even if their health plan has 0% overall rate changes during that time.
• A weighted average looks at all of the plans and insurers together. But different insurers offer plans in each region, and each insurer’s rate change is different. So the specific rate change that applies to a given enrollee can vary quite a bit from the average.

Premiums in the Tennessee exchange started out as some of the lowest in the country in 2014, but increased rapidly in the subsequent years.

As of 2022, the average full-price premium in Tennessee’s exchange was $619/month. That’s higher than the $594/month average across all 33 states that use HealthCare.gov. But 90% of Tennessee’s exchange enrollees were receiving premium subsidies that averaged $543/month. The average premium subsidy across those 33 states was about $524/month, so Tennessee’s larger premiums were offset by larger subsidies. (The subsidies are especially large in 2022, thanks to the American Rescue Plan).

Here’s a summary of how full-price rates have changed in Tennessee’s exchange over the years (keeping in mind that premium subsidies are designed to keep pace with full-price premiums, so they have grown over time as well):

• 2014: In 2014 Tennessee had among the lowest overall average rates in the country for individual market health plans. That was the first year that ACA-compliant plans were available, and rates were essentially educated actuarial guesses, since there was no claims experience on which to base them.
• 2015: Average rate increase of 12.5% (another analysis indicated a 9% increase for a 40-year-old non-smoker). This included an average rate increase of 19% for BCBSTN, 7.5% for Cigna, and 14.4% for Humana. Tennessee was one of just eight states in a PricewaterhouseCooper analysis with double-digit average rate increases for 2015. But because Tennessee had rates so much lower than the national average in 2014, their rates were still much lower than most states in 2015, even after the rate hikes. A Kaiser Family Foundation analysis of benchmark plan (second-lowest-cost silver plan) premium changes in major metropolitan areas in all 50 states found that the Nashville area still had the fifth-lowest average benchmark premium in the country in 2015, even after an increase of nearly 8 percent.
• 2016: Average increase of 28.2%. Average premium increases ranged from just 0.4% for Cigna to more than 36% for Blue Cross Blue Shield of Tennessee (BCBSTN had 70% of the market share). The overall increase was substantial, but it essentially just brought Tennessee’s lower-than-average rates more in line with rates in the rest of the country. Community Health Alliance had initially proposed a rate increase of nearly 45%, but the CO-OP ended up shutting down at the end of 2015, so that rate increase was not applicable.
• 2017: Average rate increase of 56%. The average rate increases ranged from 44.3% for Humana, to 62% for BCBSTN. Tennessee’s individual market rate increase was roughly tied with Minnesota’s for 2017, and both states trailed only Oklahoma, which had the highest weighted average increase for 2017. Cigna and Humana had originally filed average rate increases of 2% and 29%, respectively. But in early August 2016, regulators in Tennessee agreed to allow the carriers to refile new rates, after both carriers had told the state that the rates they had originally filed wouldn’t be adequate to cover claims costs. Several carriers across the country made headlines in August and September with announcements that they would exit the exchanges at the end of 2016, but UnitedHealthcare was the only insurer to exit the Tennessee exchange altogether. The fact that regulators in Tennessee allowed new rates to be filed helped to keep the carriers in the market, but it also resulted in more significant premium hikes for 2017. Carriers had asked to refile rates for 2016 during the summer of 2015, but state regulators would not allow them to do so; for 2017, regulators softened their stance in an effort to keep Cigna and Humana in the marketplace.
• 2018: Average rate increase of 28.5%. BCBSTN increased average premiums by 21.4%; Cigna increased average premiums by 36.5%. Silver plans became disproportionately expensive in 2018 in Tennessee (driving a significant chunk of the overall rate increase), as the Trump administration eliminated funding for cost-sharing reductions (CSRs). Although the official notice of the funding cut didn’t come until mid-October, TDCI confirmed in September that the additional premiums necessary to cover CSR in 2018 had already been added to silver plan rates for 2018 (pre-emptively, but presciently, since the funding was cut off by the federal government a few weeks later).
  The higher premiums for silver plans resulted in even larger premium subsidies for 2018. So although the federal government is no longer directly reimbursing insurers for the cost of CSR, they are indirectly continuing to fund CSR, via larger premium subsidies. TDCI published a document showing average premiums for 35-year-olds and 55-year-olds in each rating area of the state, but most enrollees pay far lower premiums, as their premiums subsidies cover a large portion of the premiums.
  Blue Cross Blue Shield of Tennessee issued a press release in June 2017, going into great detail about their proposed rate increase for 2018. Their actuarial memo in their rate filing indicated that their average proposed rate increase was 21.4%, but that the majority of that was due to concerns that the Trump administration wouldn’t continue to enforce the individual mandate, and the uncertainty surrounding ongoing funding for cost-sharing reductions (CSR). The press release from Blue Cross Blue Shield of Tennessee noted that of the 21.4% rate increase they proposed (which was later approved by TDCI), 14 percentage points were due to the possible lack of funding for cost-sharing subsidies, and 7 percentage points were due to concerns that the individual mandate wouldn’t be well enforced, resulting in a sicker risk pool (healthy people are the ones likely to drop coverage if the mandate isn’t enforced; sick people will maintain their coverage regardless).
  So the rate increase for 2018 would apparently have been just 0.4% if it weren’t for the Trump administration’s refusal to commit to funding cost-sharing reductions and enforcing the individual mandate. Instead, BCBSTN proposed an average rate increase of 21.4 percent, and state regulators had no choice but to approve it. Cigna noted that 14.1 percentage points of their rate increase was due to the fact that the Trump administration had not committed to funding cost-sharing subsidies.
• 2019: Average rate decrease of 12.4%. But the average benchmark plan premium decreased by 26% in 2019, which was the largest percentage decrease in the nation. The average, across all states, was a 1.5% decrease. Premium subsidies are based on the cost of the benchmark plan, so subsidies decreased by a larger margin than average premiums. In August 2018, the Tennessee Insurance Department announced approved 2019 rate changes, including rate decreases for Blue Cross Blue Shield and Cigna, which had the bulk of the state’s individual market enrollees.
• 2020: Average rate decrease of about 1.1%. But benchmark premiums dropped by 7%, leading to some people paying higher after-subsidy premiums for their coverage in 2020. In 2019, when Bright and Celtic joined the marketplace in Tennessee and Cigna and Oscar expanded their coverage areas, benchmark premiums decreased much more significantly than overall average premiums, resulting in smaller premium subsidies. So 2020 was the second year in a row that subsidy amounts dropped by more than the average premium amounts in Tennessee’s exchange (which could partially explain the decrease in enrollment since 2018; plans become less affordable when subsidies decrease by more than average premiums). Tennessee’s exchange insurers implemented rate changes that varied from a decrease of about 8% to an increase of about 3% for 2020.
• 2021: Overall average rate changes ranged from a decrease of 6% to an increase of 10%. Details available here, from the Tennessee Department of Insurance. Insurers had to submit rate filings in Tennessee by July 15, 2020. Some of the rates were approved as-filed, but the Tennessee Department of Commerce and Insurance worked with some of the insurers to reduce their proposed rates for 2021, with revised rate filings submitted by some insurers in August.

• 2022: Overall average rate increase of 4.4%. Filing details for Tennessee’s six marketplace insurers are available in SERFF, and the Tennessee Department of Commerce and Insurance published the marketing presentations that each insurer made for 2022. According to SERFF, the rate proposals for 2022 were approved as-filed, including some increases and some decreases. The weighted average rate change amounted to an increase of 4.4% for 2022.

A record-high 348,097 people enrolled in private plans through Tennessee’s exchange during the open enrollment period for 2023 coverage (for perspective, the previous record high had come the year before, when fewer than 274,000 people enrolled)

2023 enrollment hit a nationwide record high as well, on the heels of a previous record high the year before. This was due in large part to the American Rescue Plan‘s subsidy enhancements, which make subsidies larger and more widely available (those provisions have been extended through 2025 by the Inflation Reduction Act).

Here’s a look at how enrollment has changed over the years in Tennessee’s exchange:

• 2014: 151,352 people enrolled
• 2015: 231,440 people enrolled
• 2016: 268,867 people enrolled (enrollment didn’t break this level again until 2022)
• 2017: 234,125 people enrolled 
• 2018: 228,646 people enrolled 
• 2019: 221,553 people enrolled
• 2020: 200,445 people enrolled
• 2021: 212,052 people enrolled
• 2022: 273,680 people enrolled
• 2023: 348,097 people enrolled

The decreasing enrollment from 2017 through 2021 stemmed from a variety of factors:

• President Trump took office just days before the end of the open enrollment period for 2017 coverage, and immediately cut HealthCare.gov’s marketing campaign. 2017 rates were also sharply higher for people who didn’t qualify for premium subsidies.
• For 2018, the Trump administration reduced the marketing and outreach budget for HealthCare.gov, rates again increased sharply for people who didn’t qualify for premium subsidies (due mostly to uncertainty over the future of the individual mandate and the Trump administration’s decision to cut off funding for cost-sharing reductions), and open enrollment was only half as long as it had been the year before.
• Although rates decreased for 2019, they were still quite high for people who don’t qualify for premium subsidies. The GOP tax bill ended the individual mandate penalty at the end of 2018, and the Trump administration made it easier for people to opt for coverage under short-term health plans instead of ACA-compliant plans.
• For 2020, benchmark premiums (on which subsidies are based) decreased more significantly than overall average premiums in Tennessee’s exchange, making after-subsidy premiums less affordable for many enrollees.

Tennessee has a coverage gap because the state has refused to expand Medicaid under the Affordable Care Act. The federal government would pay nearly all of the cost to expand Medicaid, but the state would have to agree to allow this, and they have not done so.

As a result, Medicaid eligibility is still very strict in Tennessee, and childless adults without disabilities are ineligible for Medicaid regardless of how low their income is. Because the ACA’s premium tax credits (subsidies) aren’t available to applicants with income below the poverty level (because the law called for them to have expanded Medicaid instead), these applicants fall into what’s come to be known as a coverage gap. They are ineligible for Medicaid and also ineligible for premium tax credits to make private coverage more affordable. 

There are an estimated 118,000 Tennessee residents in the coverage gap. As of early 2023, there are only 11 states that still have coverage gaps; Tennessee is among them. The state could solve this problem at any time by accepting federal funding to expand Medicaid, but state lawmakers have thus-far refused to do so.

(South Dakota will expand Medicaid in mid-2023, and North Carolina is expected to do so by early 2024, reducing the number of states with a coverage gap. Georgia plans to partially expand Medicaid in mid-2023, albeit with a work requirement that will sharply limit the number of people who qualify for coverage.)