"Prior to ACA, private carriers of individual insurance policies could typically file rates much later in the year ... just a few months before implementing them, and could often re-file revised rates at any time if necessary. Now, individual markets will be on a calendar year bid schedule like the MAPD market, with most states requiring rates to be filed in mid-to-late spring of each year for plans that will be sold in the following calendar year.... Having to file rates so far in advance will require major operational and strategic changes at these organizations. The change represents a fundamental shift in the risk of this line of business. Overall, this shift will create significant new pricing risk for participants in the individual market[.]"

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