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2014 Premium Round – PHIAC’s Role. Shaun Gath CEO, Private Health Insurance Administration Council Presentation to Industry Sydney, 6 November 2013 Melbourne, 12 November 2013. Agenda. Legislation What’s new (nothing much) PHIAC’s approach to the task Guiding principles.

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2014 premium round phiac s role

2014 Premium Round – PHIAC’s Role

Shaun GathCEO, Private Health Insurance Administration Council

Presentation to Industry

Sydney, 6 November 2013

Melbourne, 12 November 2013

  • Legislation
  • What’s new (nothing much)
  • PHIAC’s approach to the task
  • Guiding principles
first question i f there s not much new why are we all here
First question…If there’s not much new, why are we all here?
  • Because you asked us to be here.
  • Private Healthcare Australia polled its members and advised us that, notwithstanding not much change, these sessions would be appreciated.
  • We are happy to oblige.
plus we can tell you what industry ceos said about last year s experience
Plus, we can tell you what industry CEOs said about last year’s experience…

“A vastly improved process resulting in many hours and $$ saved”

“A big positive step forward”


“We thought the process was very good”

“A better and more transparent process”

“Like it lots”

“a material improvement over recent years”

See also 2013 Stakeholder Survey at www.phiac.gov.au, p16

private health insurance act 2007 section 66 10
Private Health Insurance Act 2007 Section 66(10)

66‑10  Minister’s approval of premiums

(1)  A private health insurer that proposes to change the premiums charged under a *complying health insurance product must apply to the Minister for approval of the change:

(a)  in the *approved form; and

(b)  at least 60 days before […] the change [takes] effect.

(2)  […]

(3)  The Minister must, by written instrument, approve the proposed changed amount or amounts, unless the Minister is satisfied that a change that would increase the amount or amounts would be contrary to the public interest.

(4) […]

what we used to do
What we used to do….


Minister for Health

s.66(10) Advice



Sent to PHIAC

Technical analysis and “minimum necessary” opinion (if sought)

PHIAC – Insurer Discussions


last year it looked like this
Last year, it looked like this…
  • Technical advice and s.66(10) Advice


  • Minister for Health



DoHA liaison and observational role assisting Minister and PHIAC


key differences in 2012 13 and this year
Key differences…in 2012/13 (and this year)
  • Applications went directly to PHIAC
  • PHIAC was the primary source of advice to the Minister about premium increases
    • (Dept. retained visibility)
  • PHIAC formulated its advice applying its own judgment as to the factors bearing upon public interest
  • The Minister remained the decision-maker
how will phiac go about this
How will PHIAC go about this?
  • For us this is a relatively simple exercise: we do what we are already set up to do.
  • Our statutory objectives are:

To achieve an appropriate balance between:

(a)  fostering an efficient and competitive health insurance industry;

(b)  protecting the interests of consumers;

(c)  ensuring the prudential safety of individual private health insurers

(PHI Act, section 264-5)

  • This is the pricing task in a nutshell
key themes to our approach
Key themes to our approach
  • We want:
    • a light touch
    • the process to be transparent
    • to remove scope for confusion and surprises
    • to encourage your regular communication
  • We accept the principle that the market is the best place to set prices.
    • where there is evidence of clear and effective competition for products, PHIAC will be slow to disturb the pricing judgment of insurers
    • where the market is inefficient or failing, further inquiry may be required
what are the indicia of an efficient market for phi services
What are the indicia of an efficient market for PHI services?
  • Strong evidence of accurate and complete information about products and prices being provided to consumers
  • Portability system working efficiently
  • New entrants at times of high profitability
  • Competition for new and current members
  • Substitutable products readily available
  • Suppliers don’t have disproportionate bargaining power
by these measures
By these measures…

In 2013, the Australian PHI market seems:

  • not to be perfect or optimally efficient
  • not to be dynamically competitive, despite high profitability, as evidenced by lack of substantive new entrants
  • to be experiencing both growth but relatively low movement between insurers (“stickiness”)
  • to be dealing with an information poor consumer sector

Source: IPSOS, Health Care & Insurance 2011; ACCC, Report to the Australian Senate on anti-competitive and other practices by health funds and providers in relation to private health insurance; PHIAC, Competition in the Australian PHI Market, 2013.

competition in the australian phi market
“Competition in the Australian PHI Market”
  • PHIAC published its paper on 3 June 2013
    • Followed a discussion paper published in November 2012 which prompted 27 submissions
    • 6 submissions confidential, one partially
    • The rest are available on the PHIAC website
  • Discussion continues on the paper and issues raised on the PACU website
phiac s key observations
PHIAC’s Key Observations
  • Competition in the PHI market is best described as a “mixed bag”
  • The good news:
    • PHI has strong commercial visibility (advertising, sponsorship, longstanding brand awareness)
    • Vigorous retail presence (unlike many other countries)
    • Consumers have a strong awareness of the price of the product (cf. US experience – now changing)
    • Small funds do compete effectively with big ones
    • “general insurance only” is an emerging area for strong competitive behaviours
phiac s key observations1
PHIAC’s Key Observations
  • The not-so-good news:
    • Australian consumers are turned off by the complexity
    • Consumers exhibit strong degree of “stickiness” despite very real pricing opportunities
    • There is not much evidence that Australian PHI consumers are actually responding to price and product signals other than in some fairly narrow and highly contested areas (especially entry point, young adults caught by LHC policies for the first time).
  • In short, a mixed story.
in summary
In summary
  • We will give fair weight to the pricing judgments presented to us and generally be disinclined to second guess
  • But…
    • We will want to examine your forecasts in the insurance business and your capital projections – as we have always done.
  • We will, above all, be looking out for consumers