Filing at a Glance - Pennsylvania Insurance Department · CBC’s data warehouse. The method for calculating incurred claims in the BEP is as follows: 1. Historical fee-for-service

Filing at a Glance

Company: Capital Advantage Assurance Company

Product Name: CAAC PersonalBlue PPO - Rates

State: Pennsylvania

TOI: H16I Individual Health - Major Medical

Sub-TOI: H16I.005A Individual - Preferred Provider (PPO)

Filing Type: Rate - M.U. (Medically underwritten)

Date Submitted: 08/17/2017

SERFF Tr Num: CABC-131157380

SERFF Status: Assigned

State Tr Num: CABC-131157380

State Status: Received Review in Progress

Co Tr Num: 17-89

ImplementationDate Requested:

01/01/2018

Author(s): Anna Fulginiti, Mary Leberknight, Kayla Sokolas

Reviewer(s): Rashmi Mathur (primary)

Disposition Date:

Disposition Status:

Implementation Date:

State Filing Description:

SERFF Tracking #: CABC-131157380 State Tracking #: CABC-131157380 Company Tracking #: 17-89

State: Pennsylvania Filing Company: Capital Advantage Assurance Company

TOI/Sub-TOI: H16I Individual Health - Major Medical/H16I.005A Individual - Preferred Provider (PPO)


Project Name/Number: /

PDF Pipeline for SERFF Tracking Number CABC-131157380 Generated 08/23/2017 08:55 AM

General Information

Company and Contact

Filing Fees

Project Name: Status of Filing in Domicile:

Project Number: Date Approved in Domicile:

Requested Filing Mode: Review & Approval Domicile Status Comments:

Explanation for Combination/Other: Market Type: Individual

Submission Type: New Submission Individual Market Type: Individual

Overall Rate Impact: Filing Status Changed: 08/17/2017

State Status Changed: 08/22/2017

Deemer Date: Created By: Mary Leberknight

Submitted By: Mary Leberknight Corresponding Filing Tracking Number: CABC-131142496,CABC-131157049, CABC-131157394, and CABC-131157390for forms.

State TOI: H16I Individual Health - Major Medical

State Sub-TOI: H16I.005A Individual - Preferred Provider(PPO)

PPACA: Not PPACA-Related

PPACA Notes: null

Include Exchange Intentions: No

Additional Benefits: No

Filing Description:

CAAC Individual Comprehensive Major Medical Preferred Provider Organization PersonalBlue PPO

Filing Contact InformationStephanie Gray, Manager ActuarialServices

[email protected]

2500 Elmerton Avenue

Harrisburg, PA 17110

717-541-7269 [Phone]

Filing Company InformationCapital Advantage AssuranceCompany

2500 Elmerton Avenue


(717) 541-7000 ext. [Phone]

CoCode: 14411

Group Code:

Group Name:

FEIN Number: 45-5492167

State of Domicile:Pennsylvania

Company Type: LAH

State ID Number:

Fee Required? No

Retaliatory? No

Fee Explanation:







Rate Information Rate data applies to filing.

Filing Method: Review & Approval

Rate Change Type: Increase

Overall Percentage of Last Rate Revision: 0.000%

Effective Date of Last Rate Revision: 01/01/2017

Filing Method of Last Filing: Review & Approval

Company Rate Information

Company

Name:

Company

Rate

Change:

Overall %

Indicated

Change:

Overall %

Rate

Impact:

Written

Premium

Change for

this Program:

Number of Policy

Holders Affected

for this Program:

Written

Premium for

this Program:

Maximum %

Change

(where req'd):

Minimum %

Change

(where req'd):

Capital AdvantageAssurance Company

Increase 30.000% 30.000% $3,398,972 4,472 $11,329,908 30.000% 30.000%







Rate Review Detail

COMPANY:Company Name: Capital Advantage Assurance Company

HHS Issuer Id: 45127

PRODUCTS:

Product Name HIOS Product ID HIOS Submission ID Number of Covered

LivesCAAC PersonalBlue PPO 4472

Trend Factors:

FORMS:New Policy Forms: n/a

Affected Forms: n/a

Other Affected Forms: n/a

REQUESTED RATE CHANGE INFORMATION:Change Period: Annual

Member Months: 0

Benefit Change: None

Percent Change Requested: Min: 0.0 Max: 0.0 Avg: 0.0

PRIOR RATE:Total Earned Premium: 0.00

Total Incurred Claims: 0.00

Annual $: Min: 0.00 Max: 0.00 Avg: 0.00

REQUESTED RATE:Projected Earned Premium: 0.00

Projected Incurred Claims: 0.00

Annual $: Min: 0.00 Max: 0.00 Avg: 0.00







Rate/Rule Schedule

Item

No.

Schedule

Item

Status

Document Name

Affected Form Numbers

(Separated with commas) Rate Action Rate Action Information Attachments

1 PID Rates New Ind_17-89_Initial_CAAC_MUW-GI-PPO_Rates_RateRule_20170817.xlsm,







Attachment Ind_17-89_Initial_CAAC_MUW-GI-PPO_Rates_RateRule_20170817.xlsm is not a PDFdocument and cannot be reproduced here.







Supporting Document Schedules Satisfied - Item: Transmittal Letter (A&H)Comments:Attachment(s): Ind_17-89_Initial_CAAC_MUW-GI-PPO_RateCvLtr_Supporting_20170817.pdfItem Status:Status Date:

Satisfied - Item: Actuarial Memorandum and Explanatory Information (A&H)Comments:Attachment(s): Ind_17-89_Initial_CAAC_MUW-GI-PPO_ActMemo_Supporting_20170817.pdfItem Status:Status Date:







August 17, 2017

Ms. Johanna Fabian-Marks, Special Deputy & Acting Director

Bureau of Life, Accident and Health Insurance

Office of Insurance Product Regulation and Administration

Commonwealth of Pennsylvania Insurance Department

1311 Strawberry Square


Re: Capital Advantage Assurance Company

Individual Transitional PPO

Filing No 17-89

TOI Code: H161 Individual Health – Major Medical

Sub-TOI Code: H161.005A Individual Preferred Provider

Filing Type: Rate

Dear Ms. Fabian-Marks:

By this filing Capital BlueCross, on behalf of its wholly owned subsidiary Capital Advantage

Assurance Company, submits to the Department Individual Transitional Rates effective January

1, 2018.

The following is a summary of the rate filing:

Company Name: Capital Advantage Assurance Company (CAAC)

NAIC: 14411

Market: Individual

Effective Date: 1/1/2018

Average Rate Change: 30%

Product: PPO

Current Covered Lives: 4,472

Form Filings:

o CABC-131142496

o CABC-131157049

o CABC-131157394

o CABC-131157390

In support of this filing, I have included an actuarial memorandum with supporting exhibits, and

rate tables.

If you have any questions regarding this filing, please call me at 717-541-7269 (or via email at

[email protected]) or Mark Spitler at 717-541-6613

([email protected]). Thank you for your assistance in this matter.

mailto:[email protected]


Sincerely,

Stephanie Gray, ASA, MAAA

Manager, Actuarial Services

Capital BlueCross

Enclosures

cc: Mark Spitler, FSA, MAAA, Senior Director, Actuarial Services

Mell McKelvey, ASA, MAAA, Vice President and Chief Actuary, Actuarial Services

Patricia Wong, Corporate Counsel

hbc0905

Stephanie Gray

Page 1 of 7

Capital Advantage Assurance Company

Individual Transitional Rates

January 1, 2018

Filing 17-89

Actuarial Memorandum

Background

On November 14, 2013, the Centers for Medicare and Medicaid Services (CMS) issued a letter

to the State Insurance Commissioners outlining a transitional policy for non-grandfathered

coverage in the individual and small group health insurance markets for policies effective

January 1, 2014. The transitional policy stated that policies subject to transitional relief are not

considered to be out of compliance with the following provisions of the Public Health Service

Act (PHS Act):

• Section 2701 (relating to fair health insurance premiums);

• Section 2702 (relating to guaranteed availability of coverage);

• Section 2703 (relating to guaranteed renewability of coverage);

• Section 2704 (relating to the prohibition of pre-existing condition exclusions or other

discrimination based on health status), with respect to adults, except with respect to

group coverage;

• Section 2705 (relating to the prohibition of discrimination against individual

participants and beneficiaries based on health status), except with respect to group

coverage;

• Section 2706 (relating to non-discrimination in health care);

• Section 2707 (relating to comprehensive health insurance coverage);

• Section 2709, as codified at 42 U.S.C. § 300gg-8 (relating to coverage for individuals

participating in approved clinical trials).

On February 23, 2017, the Centers for Medicare and Medicaid Services (CMS) announced that

they will extend their transitional policy to plan years beginning on or before October 1, 2018,

provided that all such plans end by December 31, 2018. Under this federal transitional policy,

health insurance issuers may choose to continue certain non-grandfathered coverage in the

individual and small group health insurance markets that would otherwise be cancelled, and

affected individuals and small businesses may choose to re-enroll in such coverage. As noted

in the federal guidance, policies subject to the transitional relief are not considered to be out of

compliance with certain provisions of the Public Health Service Act and the Affordable Care

Act.

Page 2 of 7

Scope and Purpose

By this filing, in accordance with Act 134 and the Affordable Care Act (ACA) transitional

policy, Capital Advantage Assurance Company (CAAC), a subsidiary of Capital BlueCross

(CBC), submits rates for transitional members effective January 1, 2018.

Company Contact Information

Primary Contact Name: Stephanie Gray

Primary Contact Telephone Number: (717) 541 – 7269

Primary Contact Email Address: [email protected]

Proposed Rates

CAAC is proposing an aggregate annual 30% rate increase. The rate change does not vary by

plan.

Experience Period Claims

Base Experience Period: The base experience period (BEP) includes completed fee-for-service

paid and incurred claims for dates of service between June 1, 2016 and May 31, 2017.

Paid Through Date: Claims in the BEP are paid through July 31, 2017

Estimated Incurred but Not Paid Claims: Paid claims by date of service come directly from

CBC’s data warehouse. The method for calculating incurred claims in the BEP is as follows:

1. Historical fee-for-service claims are viewed by date of service and date of payment in a

claims triangle.

2. The claims triangle payments are then accumulated by date of service to develop factors

that represent the rate of accumulation or rate of “completion”.

3. Historical rates of completion by duration are used to derive projected rates of

completion. Some of the methods used to develop projected completion factors are

averages (e.g. harmonic averages, time weighted averages, geometric averages) and

regression methods. Numerous items are considered when viewing these averages or

regression statistics, such as the impact of high claims on perceived completion patterns.

4. For durations that exhibit a projected completion factor greater than the Valuation

Actuary’s chosen threshold (e.g. 80% complete), cumulative paid and incurred claims

are divided by the projected completion factor to arrive at ultimate incurred claims. For

durations that are less than the chosen threshold, a projection methodology is used.

Similar to completion factor development, projection methodologies are worthy of a

lengthy discussion. In general, an ultimate incurred claims PMPM is derived by

projecting a recent 12-month period to the current month(s) and seasonally adjusting.

5. With all months having both a cumulative paid amount and an estimated ultimate

incurred amount, the completion factors used in pricing are calculated by taking the


Page 3 of 7

quotient of the two. Allowed completion and incurred completion are assumed to be

identical.

6. Both allowed and paid claims in the BEP are completed by applying completion factors

by incurred month developed in Step 6.

𝐵𝐸𝑃 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚𝑠 = ∑𝐵𝐸𝑃 𝑃𝑎𝑖𝑑 𝐶𝑙𝑎𝑖𝑚𝑠 𝑏𝑦 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝑀𝑜𝑛𝑡ℎ

𝐶𝑜𝑚𝑝𝑙𝑒𝑡𝑖𝑜𝑛 𝑏𝑦 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝑀𝑜𝑛𝑡ℎ

𝐵𝐸𝑃 𝐴𝑙𝑙𝑜𝑤𝑒𝑑 𝐶𝑙𝑎𝑖𝑚𝑠

= ∑𝐵𝐸𝑃 𝑃𝑎𝑖𝑑 𝐶𝑙𝑎𝑖𝑚𝑠 + 𝐵𝐸𝑃 𝑀𝑒𝑚𝑏𝑒𝑟 𝐶𝑜𝑠𝑡 𝑆ℎ𝑎𝑟𝑒 𝑏𝑦 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝑀𝑜𝑛𝑡ℎ

𝐶𝑜𝑚𝑝𝑙𝑒𝑡𝑖𝑜𝑛 𝑏𝑦 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝑀𝑜𝑛𝑡ℎ

Rx Rebates: Prescription drug claims are net of Rx rebates.

Capitated Services: There are no capitated services attributable to this segment.

Projection Factors

Trend Factors: Trend levels reflect our best estimate of changes in utilization, provider

reimbursement contracts, the network of facilities and providers, disease management initiatives

and the impact of utilization management.

The following is a description of considerations used to determine trend.

1. Base Cost/ Change in hospital and physician contracting: The contracted increase in

reimbursements to hospitals and physicians is the basis of cost trends. CAAC uses a

hospital and physician contracting model to determine future trends. This model

contains all known contracted payment increases, as well as estimated increases in

provider payments.

2. Utilization Considerations:

a. Intensity of medical services rendered

b. Changes in place of service (e.g. continued migration of inpatient stays to

outpatient setting)

c. Further migration from brand prescription drugs to generic prescription drugs

d. Favorable impacts of value based benefits designs

3. Intensity: Intensity is defined as the amount of inputs used to provide each unit of

service. This can best be seen in an example:

Year 2017

Type of Service Units Cost per Unit

X-Ray 1 $200

MRI 1 $5,000

Total 2 $5,200

Year 2018

Page 4 of 7

Type of Service Units Cost per Unit

X-Ray 0 $200

MRI 2 $5,000

Total 2 $10,000

Total Annual Trend 92%

Please see Exhibit A – Trend for all trend values. Trend values and weights are taken directly

from 1/1/2018 Small Group CAAC filing (CABC-131022141), as CBC expects the individual

transitional claims trend to more closely align with the small group market versus the individual

ACA market.

Morbidity Adjustment: No morbidity adjustment is applied.

Benefit Adjustment: No benefit adjustment is applied as the benefits in the projection period

are the same as those in the BEP.

Non-Benefit Expenses and Profit & Risk

Administrative Expense Load:

1. Administrative Expense: Calculated using an allocation method from CAAC’s finance

department, and trended to the rating period. Costs are allocated according to results

reported through a company-wide questionnaire. On an annual basis, each cost center

within the company completes a questionnaire listing the distribution of costs (in

percentage terms) by product as well as by market segment. For example, the

questionnaire will ask what percentage of time is spent on PPO versus HMO versus

Drug versus Medicare. And separately will ask what percentage of time is spent on

large group, small group, individual, and government programs. Using those

distributions, all costs needed to perform the business are allocated to the proper market

segments and lines of business. The administrative expense applied in the rate

development is the total expense allocated to CAAC individual products.

2. Broker Expense: CAAC’s transitional YTD 2017 broker fee PMPM.

3. Identity Theft Coverage: Identity protection offering will include the following

components:

a. Credit monitoring – Monitors activity that may affect credit

b. Fraud detection – Identifies potentially fraudulent use of identity or credit

c. Fraud resolution support – Assists members in addressing issues that arise in

relation to credit monitoring and fraud detection

Profit (or Contribution to Surplus) & Risk Margin:

4. Contingency

Taxes and Fees:

Page 5 of 7

1. Fee for Patient-Centered Outcomes Research Trust Fund (PCOR): As per the Notice of

Proposed Rulemaking for Fees on Health Insurance Policies and Self-Insured Plans for

the Patient-Centered Outcomes Research Trust Fund (REG-136008-11), 77 Fed. Reg.

22691: For policy years ending on or after October 1, 2013, and before October 1,

2014, the applicable dollar amount in $2 per member per year ($0.17 PMPM), trended

annually. At an estimated trend of 4%, the 2018 projected fee is $0.20 PMPM.

2. Health Insurer Fee (HIF) – Section 9010 of PPACA and Section 1406 of the

Reconciliation Act (which modified PPACA) refer to HIF. The fee is a fixed-dollar

amount distributed across health insurance providers: $8 billion in 2014, $11.3 billion

in 2015-2016, suspended in 2018, and $14.3 billion in 2018.

3. Premium Tax: Premium tax does not apply to CAAC.

Please see Exhibit B – Retention for all retention values.

Rate Development

Projected Paid and Incurred Claims are calculated as follows:

1. Gather claims experience as described in the Data section above.

a. Base Experience Period (BEP) Paid Claims, Capitation, and Rx Rebates

b. BEP Member Months

2. Develop BEP Paid and Incurred Claims:

𝐵𝐸𝑃 𝑃𝑎𝑖𝑑 𝑎𝑛𝑑 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚𝑠 = 𝐵𝐸𝑃 𝑃𝑎𝑖𝑑 𝐶𝑙𝑎𝑖𝑚𝑠

𝐶𝑜𝑚𝑝𝑙𝑒𝑡𝑖𝑜𝑛 𝐹𝑎𝑐𝑡𝑜𝑟

The development of completion factors is described in Experience Period

Premium and Claims above.

3. Develop the BEP Paid and Incurred Claim PMPM:

𝐵𝐸𝑃 𝑃𝑎𝑖𝑑 𝑎𝑛𝑑 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚 𝑃𝑀𝑃𝑀 =𝐵𝐸𝑃 𝑃𝑎𝑖𝑑 𝑎𝑛𝑑 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚𝑠

𝐵𝐸𝑃 𝑀𝑒𝑚𝑏𝑒𝑟 𝑀𝑜𝑛𝑡ℎ𝑠

4. Develop Trended Claim PMPM: Using the aggregate trend described in the Projection

Factors section above, trend the BEP Paid and Incurred Claim PMPM from the midpoint

of the experience period to the midpoint of the rating period.

𝑇𝑟𝑒𝑛𝑑𝑒𝑑 𝐶𝑙𝑎𝑖𝑚 𝑃𝑀𝑃𝑀= [𝐵𝐸𝑃 𝑃𝑎𝑖𝑑 𝑎𝑛𝑑 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚 𝑃𝑀𝑃𝑀]× (1 + [𝑇𝑟𝑒𝑛𝑑%])𝑇𝑟𝑒𝑛𝑑 𝑀𝑜𝑛𝑡ℎ𝑠/12

5. Develop Projected Paid and Incurred Claim PMPM:

Page 6 of 7

𝑃𝑟𝑜𝑗𝑒𝑐𝑡𝑒𝑑 𝑃𝑎𝑖𝑑 𝑎𝑛𝑑 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚𝑠 𝑃𝑀𝑃𝑀= [𝑇𝑟𝑒𝑛𝑑𝑒𝑑 𝐶𝑙𝑎𝑖𝑚 𝑃𝑀𝑃𝑀] × [𝐵𝑒𝑛𝑒𝑓𝑖𝑡 𝐴𝑑𝑗𝑢𝑠𝑡𝑚𝑒𝑛𝑡] × [𝑀𝑜𝑟𝑏𝑖𝑑𝑖𝑡𝑦 𝐴𝑑𝑗𝑢𝑠𝑡𝑚𝑒𝑛𝑡]

The Benefit Adjustment and Morbidity Adjustment are discussed in the

Projections Factors section above.

6. Develop Adjusted Projected Paid and Incurred Claim PMPM for capitation and Rx

rebates.

𝐴𝑑𝑗𝑢𝑠𝑡𝑒𝑑 𝑃𝑟𝑜𝑗𝑒𝑐𝑡𝑒𝑑 𝑃𝑎𝑖𝑑 𝑎𝑛𝑑 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚𝑠 𝑃𝑀𝑃𝑀= [𝑃𝑟𝑜𝑗𝑒𝑐𝑡𝑒𝑑 𝑃𝑎𝑖𝑑 𝑎𝑛𝑑 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚𝑠 𝑃𝑀𝑃𝑀]+ [𝐶𝑎𝑝𝑖𝑡𝑖𝑎𝑡𝑖𝑜𝑛 𝑃𝑀𝑃𝑀] + [𝑅𝑥 𝑅𝑒𝑏𝑎𝑡𝑒𝑠]

7. Develop Total Required Premium PMPM:

𝑇𝑜𝑡𝑎𝑙 𝑅𝑒𝑞𝑢𝑖𝑟𝑒𝑑 𝑃𝑟𝑒𝑚𝑖𝑢𝑚 𝑃𝑀𝑃𝑀

=

[𝐴𝑑𝑗𝑢𝑠𝑡𝑒𝑑 𝑃𝑟𝑜𝑗𝑒𝑐𝑡𝑒𝑑 𝑃𝑎𝑖𝑑 𝑎𝑛𝑑 𝐼𝑛𝑐𝑢𝑟𝑟𝑒𝑑 𝐶𝑙𝑎𝑖𝑚𝑠 𝑃𝑀𝑃𝑀] + [𝐴𝑑𝑚𝑖𝑛 𝑃𝑀𝑃𝑀] + [𝐵𝑟𝑜𝑘𝑒𝑟 𝑃𝑀𝑃𝑀]

+ [𝐼𝑑𝑒𝑛𝑡𝑖𝑡𝑦 𝑇ℎ𝑒𝑓𝑡] + [𝑃𝐶𝑂𝑅]

1 − [𝐻𝐼𝐹%] − [𝑃𝑟𝑒𝑚𝑖𝑢𝑚 𝑇𝑎𝑥%] − [𝐶𝑜𝑛𝑡𝑖𝑛𝑔𝑒𝑛𝑐𝑦%]

Admin PMPM, Broker PMPM, Patient-Centered Outcomes Research Trust Fund (PCOR),

Identity Theft, Health Insurer Fee (HIF), Premium Tax, and Contingency development are

described in the Non-Benefit Expenses and Profit & Risk section above.

8. Develop Total Recommended Base Rate Premium PMPM: The Recommended Base

Rate Premium PMPM is CAAC’s final recommendation based on actuarial analysis.

The development of Total Recommended Base Rate Premium is shown in Exhibit C – Rate

Development.

Attachments and Exhibits

Rates: File: Ind_17-89_Initial_CAAC_MUW-GI-PPO_Rates_RateRule_20170817.xlsm

Rate Development: File: File: Ind_17-89_Initial_CAAC_MUW-GI-

PPO_RateDev_Supporting_20170817.xlsm

Exhibit A – Trend

Exhibit B - Retention

Exhibit C – Rate Development

Page 7 of 7

Actuarial Statement

I, Stephanie Gray, ASA, MAAA, am of the opinion that this filing is in compliance with the

applicable Federal and State Laws and Regulations concerning the Patient Protection and

Affordable Care Act and the Health Care and Education Reconciliation Act of 2010.

I, Stephanie Gray, ASA, MAAA, do hereby certify that:

1. This filing has been prepared in accordance with the following:

a. Actuarial Standard of Practice No. 5, “Health and Disability Claims”

b. Actuarial Standard of Practice No. 8, “Regulatory Filings for Rates and

Financial Projections for Health Plans”

c. Actuarial Standard of Practice No. 12, “Risk Classification”

d. Actuarial Standard of Practice No. 23, “Data Quality”

e. Actuarial Standard of Practice No. 25, “Credibility Procedures Applicable to

Accident and Health, Group Term Life, and Property/Casualty Coverage”

f. Actuarial Standard of Practice No. 26, “Compliance with Statutory and

Regulatory Requirements for the Actuarial Certification of Small Employer

Health Benefit Plans”

g. Actuarial Standard of Practice No. 41, “Actuarial Communications”.

Stephanie Gray, A.S.A., M.A.A.A.

hbc0905

Stephanie Gray

Documents

Filing at a Glance - Pennsylvania Insurance Department · CBC’s data warehouse. The method for calculating incurred claims in the BEP is as follows: 1. Historical fee-for-service