Humana Inc. (HUM)
NYSE: HUM · Real-Time Price · USD
215.23
+0.28 (0.13%)
At close: Apr 24, 2026, 4:00 PM EDT
214.38
-0.85 (-0.39%)
After-hours: Apr 24, 2026, 7:56 PM EDT
← View all transcripts

TD Cowen 44th Annual Health Care Conference

Mar 5, 2024

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Good morning, everybody. Gary Taylor, cover healthcare facilities and managed care. My pleasure to host Humana this morning. Most of you, I'm sure, know Humana's the second-largest, Medicare Advantage health insurer in the U.S. They also operate a PBM, home health, and physician clinics in their CenterWell segment. We have the Chief Executive Officer, Bruce Broussard, and Chief Financial Officer, Susan Diamond, this morning. So welcome to the TD Cowen Conference. Thanks for being here.

Bruce D. Broussard
CEO, Humana Inc

Thanks for having us.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

I think I'll start with the 8-K this morning. So you reiterated the guidance for 2023 and 2024. I think we were hoping maybe for a little more commentary around utilization and what you're seeing. So anything there you wanna update us on?

Susan M. Diamond
CFO, Humana Inc

Yeah, sure. So as is always the case, this time of year, we're always reviewing all of the sort of leading indicators, particularly across the Medicare book. I would say, you know, think about things like membership growth and the mix and composition of that membership growth, better visibility into premium and risk scores, with the CMS reimbursement. Certainly watching admission levels, which I'll speak to in a little bit more detail, but also Part D, emerging trends, which complete more quickly, you know, administrative costs. And then prior year development is something we would also watch very closely. I would say this year, in light of the regulatory changes that were implemented on January 1 around the utilization management programs, those sort of results are also something we're watching very closely in terms of actual expectations or actual versus our expectations.

I would say at the highest level, all in, I would say things are generally in line with what we've expected, so nothing that's giving us any significant concern in what we're seeing. I'll start with prior year development. You know, we're always watching this time of year to see how our year-end reserves ultimately held up. I would say with the January paid claims in the aggregate, you know, very consistent with what we had reserved to you at year-end. We did see some positive development in our inpatient unit costs and physician cost estimates, that we talked about at year-end, but that was largely offset by some negative restatement on the non-inpatient side. But again, all in, in line with expectations, as it respects prior year development.

Admission levels that we're watching very closely are trending up year-over-year, which we anticipated because of the Two-Midnight Rule changes, which we had always anticipated would lead to observation stays that were historically submitted now being submitted and paid and approved as an inpatient stay. So we are seeing that. The other thing we're watching is the actual avoidance rates relative to our utilization management programs. I would say initially, at the start of the year, they were slightly lower than we had anticipated, so we weren't seeing as much impact. Those have continued to improve each week. I would say with where they're performing at now are very close to what our expectations were, so feeling pretty good about what we're seeing.

We are gonna have to watch denial rates over a longer period of time, just to see if those patterns change relative to historical. I would say initially, we are seeing some higher appeal rates. And that's not completely unexpected, I think, as we and the providers are navigating the changes. I think we're all trying to sort of understand the rules and are we interpreting them the same. So I'd say what we're seeing now does see some higher appeal rates, natural overturn rates. So one thing we'll watch is, does the sort of remaining tail of the appeal sort of timeline result in lower appeals in the future than we would have historically seen? We're not counting on that right now. And again, that will take some time to further evaluate.

I would say of the other emerging sort of leading indicators that I referenced, I would say there's nothing really of note that we would say, you know, requires calling out in terms of significantly positive or negative. The one thing I will say is, you know, typically by this time, we would have our early view of February paid claim restatements. I would say, unfortunately, just given the Change Healthcare disruption that we're all navigating, that is much more difficult to assess. You know, with the date of the incident that happened, you know, it did impact inventory levels, obviously, beginning on that date and then paid claims towards the end of the month.

So we would say until that is ultimately resolved and the backlog of inventories worked through, it will limit to some degree our ability to fully assess sort of the paid claims, which, as you guys know, will impact our review of prior year development, but also as we get further into the first quarter, sort of the inpatient unit costs and then the non-inpatient claims, which are largely dependent on those paid claim levels. The one final thing I would note is, and some of you have asked about this, is the Doc Fix that's being proposed in the spending bill. They as of 1/1, a 125 basis point adjustment was implemented, which was contemplated in our plan. The current proposals, I think, will be voted on this week, suggest that that get rolled back. So that would be a headwind.

You can think of it as about $150 million in total. So certainly something I'd prefer not to have to deal with. It is an emerging headwind, assuming that that does get approved, which we think is highly likely. But something I think in the context of the overall plan, something that we would look to manage.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Okay. I'm gonna take the question list and throw it out the window 'cause I wanna follow up on a lot of that. Maybe just starting with I wanna make sure I understood you'd used this term avoidance rate. I'm not sure I understand exactly what you're talking about there. So can you just explain that a little bit and what you're watching on that one?

Susan M. Diamond
CFO, Humana Inc

Sure. So our utilization management programs are designed. A provider will submit, say, an inpatient admission authorization. We will review sort of the clinical sort of notes underneath that and make a determination whether we think an inpatient admission is, in fact, necessary. Oftentimes, you know, the impact that we see from those programs is a what we call a redirection or avoidance rate of an inpatient stay. It gets adjusted to an observation stay, which has a much lower unit cost associated with it. And so that, again, is something we watch very closely in real time. We have an expectation of what we think the avoidance rate will be for all submitted authorization requests. And that's what initially, like I said, we saw wasn't quite where we thought it would be after the Two-Midnight Rule changes.

But then over the course of the weeks, there was some retraining and other things as people got accustomed to the new changes and currently then running much more in line with what we expected.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

It was running, it was running worse than you thought initially or?

Susan M. Diamond
CFO, Humana Inc

Initially, it was running lower. Right. So you'd say for every 100 submissions, how many will get redirected? We were seeing fewer redirections than we initially had anticipated. But then that improved over the weeks where now it's running more like we would expect.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Are you yet at the place that sort of I mean, can you quantify Two-Midnight Rule anymore, I guess? Where I've struggled a little bit is, I mean, my understanding is that they clarified the reg. It was kind of two-faced. It was like, "You're subject to the reg. We're clarifying that, but you're still allowed to do clinical review. The MACs and the RACs can't for fee-for-service, but you can still do it," you know, for MA and some of your competitors have put out transmittals. Like, "We're not changing anything." They've put that in the public sphere to their hospital providers. And then also, we're tracking nationally observation rates with the thought that the inverse of that would perhaps, you know, be the best, you know, indicator of, you know, short-stay admission.

In that latest data, it still seemed like observation rates hadn't, you know, come down a lot. So anyway, I'm just trying to sort of circle. Like, in your is there a way to sort of quantify in your guidance, like, what you think the Two-Midnight Rule is to earnings or to trend or just, you know, something to help us think about it?

Susan M. Diamond
CFO, Humana Inc

Yeah. I don't think we've given any disclosure previously on exactly what the impact was. As we assess, to your point, the underlying utilization management programs remain intact. But there was some clarification in terms of how to interpret sort of the expectation of how long a patient might stay in the hospital. So as we assess that, you know, we really looked at the duration of the stays. We've seen historically the avoidance rates we would see. Largely, we assume that for stays that were, you know, three or more nights in length, that we expected that you would see much less impact as a result of the UM programs relative to historical. The shorter duration stays, the one- and two-night stays, we continued to have meaningful impact where an observation stay was likely would continue to prove more appropriate.

So I would say in terms of at the time of bids, what we anticipated, you know, without being extremely specific, I would say think of it between, say, 50 to 75 basis points in terms of impact, in terms of the gross impact of that change, which we would have incorporated it into our pricing. As we talked about in the fourth quarter, you know, one thing we thought we were seeing, which was not initially anticipated, was additional provider behavior change where they would potentially have organically submitted observation stays historically, that they're now, in light of the changes to Two-Midnight Rule, are now actually submitting as inpatient stays, so an absolute increase in the overall authorization volume. We mentioned we saw some of that in the fourth quarter.

And so given the way we've thought about, you know, our 2024 estimates and jumping off that fourth-quarter baseline, you can think of that as also now being incorporated into our estimates. So it's part of the overall MLR change that we've stepped up to in 2024. And it's something we'll have to continue to monitor. We did mention that we did see a reduction in observation stays on an absolute basis. The data was still quite early. But we saw it, you know, with December paid claims, mostly from the month of October and the January restatements. We picked some negative restatements on non-inpatient.

We'd still say observation stays still are trending negative in the fourth quarter, which, again, we think further supports the fact that we are seeing some level of provider behavior change, which, again, at the end of the day, you can think of resulting in a higher overall unit cost. So I think, you know, we've been preaching how we've thought about it in our 2024 plan. As I said, our initial indicators seem to suggest that we're trending, you know, currently in line with those expectations. But the appeal rates is something that will take a little bit longer to assess that we'll have to continue to watch.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Gotcha. That's helpful. And then, Change, that was like a new question was gonna be top of my list. And you guys have proactively talked about it. Can you give us a little sense of, are you just using, you know, Change for your, or tell us how you're using Change? Are, you know, CenterWell's using it to send it to different payers? You're using it, you know, to downstream pay, you know, providers out of Humana. And do you have other EDIs that you've used historically, and you're able to shift some of that around? Or how are you handling the outage?

Susan M. Diamond
CFO, Humana Inc

Yeah. I would say, to be honest, we're still trying to evaluate all of the impacts. I would say the ones that, you know, we're certain of, you know, about 15% to 20% of our medical claims are dependent on Change, where they will come through Change, before coming to us in terms of claim submissions and ultimate payments. It's a higher percentage in terms of impact to our dental claims. Although interesting enough, on the dental side, we also rely on them for the submission of certain clinical documentation. So we may be receiving the claim but can't process it because we don't have the actual clinical documentation.

So that's some of the complexity that we're trying to figure out is, what's the impact of this not only on paid claims but also on inventory levels, both of which would impact how we think about claim restatements and, you know, the completion lags and all of that. So it's a significant impact, given the magnitude. But I think we also use it for things like verifying eligibility for dual-eligible status. And so that's more on the sales sort of front end, having confidence in whether someone's dual-eligible and having confidence you're enrolling them in the right plan. So there are things like that where we also have operational dependencies. To your point, I think everyone's looking for workarounds. So that's something we also have to figure out is, you don't necessarily know in real time who's figured out a workaround.

So we're just monitoring inventory levels, paid claim levels to try to get a sense for that, as well as working with Availity and others to understand what they're seeing and sort of who they're working with to better understand. The longer this goes on, the more important that will be, as we continue to assess the impact.

Bruce D. Broussard
CEO, Humana Inc

We do see our primary clearinghouse is Availity. And we are seeing a pretty fast movement from Change to other clearinghouses, of which Availity is probably one of the more predominant ones going, that we do see over time, irrelevant if whatever Change is able to correct, that there's a lot of that business will move into another clearinghouse.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Gotcha.

Susan M. Diamond
CFO, Humana Inc

One thing I would say just to reiterate 'cause I know it sounds like, "Oh, my gosh. You don't have all these claims," which I certainly would rather have them than not have them. I will say, just keep in mind, this time of year in the first quarter, you know, given that we always require a 60-day lag in terms of how we book, it will have less impact technically to how our first-quarter results ultimately play out. You know, we have real-time visibility to inpatient, you know, utilization levels, the avoidance rates, like I said. But we would largely be relying on trending and other things for purposes of, you know, unit cost and non-inpatient in the first quarter generally.

Certainly, the longer this goes on, if it carries into the second quarter, you know, is something we'll have to be mindful of, just in how long it takes to work through the backlog and really assess all the implications.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Yeah. I was gonna ask about that. I mean, just your reserving approach in the absence of seeing this, hopefully, you wouldn't assume the claims don't actually exist. So you reserve consistently. And I guess if when we get to if it got fixed fairly quickly somewhere in the 2Q is when then we'll figure out if that reserving approach was conservative or inadequate or whatever and just add a little more variability to maybe seeing that reserving approach.

Susan M. Diamond
CFO, Humana Inc

Yeah. I think that's exactly right. And so as an example, even though, you know, we technically know what February paid claims, they obviously look positive as you would expect them to because we're, in theory, missing some claims. So we will assume that is not real and that we will see further claims come in in the meantime. I think if this does continue, you know, getting granular in terms of the percentage of claims for inpatient versus physician versus other things will become increasingly important so that we can have a better understanding of what we can have more confidence in versus less, depending on the order of magnitude of impact.

Bruce D. Broussard
CEO, Humana Inc

Again, just keep in mind that the providers are obviously focused on getting their claims processed. There are other options for them.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Yeah.

Bruce D. Broussard
CEO, Humana Inc

And so I do see that even though Change Healthcare might not be able to completely deal with their issues, the industry will deal with the issue in another way.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Yeah.

Bruce D. Broussard
CEO, Humana Inc

Just, there will be other clearinghouses that will clear. CMS has gotten involved in this. And they are actively bringing together the other clearinghouses to help out.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Got it. And then on the Doc Fix, two questions. I guess one, the most direct one is, I mean, $150 million is maybe $0.80 or so a share. So if this gets finalized, I mean, given the other given the trend challenge is already in place for 2024, I mean, is that just de facto? We do the math the way I just, you know, sort of did? Or is there opportunity where you think some of that could be offset? Or is there any how would you how would you want investors to think about that?

Susan M. Diamond
CFO, Humana Inc

Yeah. So I think, you know, we reiterated our guidance this morning. We're aware of the proposed change. We are assuming it gets implemented as proposed. So you can think of us as expecting that within our reaffirmation today. And I would say, again, while I'd prefer not to have it.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Right.

Susan M. Diamond
CFO, Humana Inc

You know, then have it. It's something that I think is in the context of the overall plan and what we're seeing as some of the emerging sort of leading indicators that we feel comfortable that we can address.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

And then just thinking about bids, I mean, Congress kind of routinely, like, fixes this or so you know, I, I think 2021 was the last time we had, like, a midyear or early year sort of change. So I mean, just why wouldn't you just bid, assuming conversion rate's gonna be flat and Congress ultimately will fix it? I mean.

Susan M. Diamond
CFO, Humana Inc

Yeah. I think and we've been having this debate internally. But, you know, 2021 is when they, you know, gave the additional payment. It was supposed to be recouped in initially the first year. And then, obviously, that didn't happen. And they've been taking a portion of it. So they have taken a portion of it back. Unfortunately, what was further, you know, expected to take back this year, they've now proposed to reverse. So I do think even though they are going to propose another cut for 2025.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Yeah.

Susan M. Diamond
CFO, Humana Inc

I think we've talked internally. Just given, you know, what we've seen, I think, in light of the trend and everything else we're navigating for 2025, we will likely take a more conservative position on this and assume that it will ultimately not be implemented. Then ultimately, you know, we've talked with government affairs about the need to try to sync up these processes better between CMS and the rate notice and how that works. Ultimately, we get reimbursed for it to the degree there's a change. It's just on a lag, but it does prove challenging in terms of the way the pricing cycles work. But I think in light of everything we're navigating, we will not take an aggressive approach to whatever might be proposed, just given the history.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Okay. Well, that was super helpful. Now, I'm gonna go back to the regularly scheduled agenda here. But that was a good update. Glad we got to that. I wanna step out just big picture for a minute and think about 2025 and your latest thoughts. I mean, my I've written in my personal view, I think, the six largest MA plans, I think, all are gonna earn below target margins this year. Not everyone's yet conceded that, you know, to the marketplace. But the combination of the trend acceleration we saw through 2023 and our my view or our analysis of the benefits for 2024, I think it's the same, you know, margin challenge for everyone.

And if, if that's right, our thought is, we are gonna see maybe for the first time some material benefit reductions in 2025 and a pivot towards a little more focus or more focus on margin by the industry. But you don't get the benefit of knowing that in advance. You've gotta do the usual game theory that you always have to deal with. But it's maybe higher stakes, heading into 2025. So give us just kinda your latest thoughts on balancing enrollment versus margin because I get a lot of questions about, you know, how much could they cut? You know, what could they do? What's subject to TBC limits? You know, what's not? And I think I think what technically you could do in terms of benefit and margins probably still exceeds competitively what you'd be willing to do. But I'd like your latest kinda thoughts on that.

Bruce D. Broussard
CEO, Humana Inc

Yeah. I would say overall, Gary, is that we are oriented to margin this year. We do believe the industry is not sustainable at this level. Even in our 2023 pricing, we priced for 2024, we priced for profitability. Obviously, the fourth quarter utilization and the things that happened changed that outlook and changed our outlook for 2024. But we do feel and are oriented to pricing for the proper profitability in the industry. Now, it might take us two years to get there. But we do believe it's required. And we see that I think in your note at one time, you said, "We're at a trough within the industry margins." And we agree with that.

We agree that there is going to be changes within not only the regulatory side, but we just see competitively that, we, we don't see the competitors being able to continue to be pricing at this level. At the same time, we also see the great opportunities as, as growth continues 'cause we think the value proposition for membership will continue to, have good membership growth. And in that context, we see the ability for us to also see that as the book ages, to continue to see, natural increase in our in our revenue side as a result of risk adjustment. And then lastly, we see margin opportunity in the productivity side. And I think you've seen the organization take great, progress in the productivity area. And we continue to see that as an ongoing great opportunity, both in being efficient, which we've always tried to.

But a lot of the investments we made a few years ago are starting to really show their proof there, and specifically on the technology side. So we see margin at a low. We see pricing required to create sustainability. We are committed to that as a company. And the ability for us to build from that, we see both growth, the aging of the book, and the productivity as being a great opportunity for us to see margin enhancement.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Maybe, maybe I'll put the same question a little more directly the way sometimes investors ask it ask it to me. But is there still, you know, sort of that game theory on market share enrollment versus benefit? Is, is that still relevant in your 2025 bids, such that you're you wouldn't do the maximum you technically could do in year one? And that, that is why.

Bruce D. Broussard
CEO, Humana Inc

Yeah.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

You're anticipating, like, a multiyear margin recovery. Is that still?

Bruce D. Broussard
CEO, Humana Inc

Yeah.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Part of the thought process?

Bruce D. Broussard
CEO, Humana Inc

Great nuance in the question. Yes. What we will continue to have a view of what our competitors are doing. That would be a natural thing we would do. We would we would price with the, the view of getting to our, our, our target margins in a two-year period of time. And so that price if we could accelerate it earlier, then we would do that. So the competitive nature would sort of put a balance on that. But we wouldn't compromise that margin improvement over less than two years—more than two years, sorry.

Susan M. Diamond
CFO, Humana Inc

Gary, I would say to add to that, you know, while the industry talks about averages a lot in terms of what the average margin is and, you know, we've been pressed on this, right, obviously, our capitated, you know, plans that are more capitated are doing fine, which means those that are non are not doing quite as well. And so I would say, as an industry, you know, there are plans that are not performing well that are seeing disproportionate growth. And that's true of everyone in the industry. And so I think while the averages are interesting, what's more relevant, I think, is ultimately sort of how each company decides to make changes to the products that we know are not sustainable, as Bruce suggested.

So that's where we've done a lot of broker and consumer research to really inform sort of how do consumers and brokers think about the trade-off choices? And how can we best position the plans at a more sustainable margin level that still will be highly attractive to consumers that may pose growth? I think all of us will have to address that. I think we'll all be oriented to protecting plans, like the D-SNPs and things that do deliver against the expected margin profile where there are other types of plans where I think we all have work to do, to create a more sustainable margin profile going forward.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Got it. I wanna get into Advance Notice, a little bit. So, you know, CMS published, you know, a 16 basis points cut, including about a 15 basis points STAR headwind for the whole industry. So let's just talk exclusive of STARs, roughly, you know, zero-ish. But, your own 8-K of kind of running through, you know, the impact on your plans and what I've heard from, I guess I won't name the tickers. But most of the other large plans are exclusive of STARs, you know, coming to something that looks more like at least negative 1%, you know, before you get into company-specific STAR ratings so that, how are you thinking about that? So, and we've heard we've talked to some of the actuarial firms, as well. And then obviously, the Better Medicare Alliance put out a piece, a week or so ago saying, you know, negative 1%.

So is this something we should view as, you know, an error? Or is that too strong a word? Is it just that the larger plans are having more V28 impact? Is it because CMS created these new normalization factors for MAPD versus PDP? Like, I feel like everyone is circling that the rate notice understates, you know, the magnitude of the cut. But I don't feel like the ducks are sort of yet in a row on, like, what the message to CMS is. And maybe I'm wrong on that based on what we're hearing. But tell me how you guys are thinking about that and how you're asking CMS to respond to it.

Bruce D. Broussard
CEO, Humana Inc

Yeah. First, it doesn't reflect the utilization that's going on in the industry.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Well, yeah. Not even close.

Bruce D. Broussard
CEO, Humana Inc

And I think that's one of the large messages that we are bringing to them, not only through the fourth quarter, even what they incorporated in the restatements and the assumptions of.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Well, yeah. Bringing the four-year trend adjustments down after the year just had.

Bruce D. Broussard
CEO, Humana Inc

Yeah.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Like, isn't actuarial.

Bruce D. Broussard
CEO, Humana Inc

Right.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Area.

Bruce D. Broussard
CEO, Humana Inc

So you see, you know, a lot of energy around that.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Okay.

Bruce D. Broussard
CEO, Humana Inc

Now, the normalization, and MRA, the normalization, you know, there that area, we've also commented on because we do think that there is some calculation, corrections that need to be made there. And those two areas are probably the largest areas that we're oriented to, to be able to correct. But the biggest, I think, impact will be in the area of the utilization side.

Susan M. Diamond
CFO, Humana Inc

Gary, I do think it is the normalization and the way that they have reflected it in their summary, which is why there's a disconnect between what they have suggested and what the industry has largely suggested around whether it's negative or not. And I think that's fairly consistent. We all agree with that. The absolute level of impact, as you said, will vary, particularly based on how penetrated your risk book is. I think trying to directly compare what we might be saying to others, it's a little bit complicated 'cause it's relative to what you expected, not.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Yeah.

Susan M. Diamond
CFO, Humana Inc

So versus and we've all said, "Look, while we know we have a different point of view from CMS on the impact of V28, and it will vary, that's not the source of our difference. We know what that we've always known what that would be and has been incorporated. It's really what Bruce suggested. It's the negative restatements, which we would not have expected and do not think are reflective of trend. And then this technically resolves it." I think the industry is very aligned on those two challenges that we're all giving feedback to CMS. And historically, we have seen, you know, reasonable, meaningful improvement between the preliminary and the final. We would hope to see, you know, that and then some in light of the feedback that we're providing. And, you know, we'll just have to see ultimately what the final rate notice incorporates.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Is there any besides kinda the historic, you know, trajectory where the final notice usually is better? Is there any solid basis yet that the arguments are finding purchase with this administration? Because they really seem to have a view that, I mean, literally, that the industry cries, "Well, if they're never actually gonna cut benefits, and, you know, somehow you don't need a rate update even though there's underlying cost trend." And it seemed to be a challenging risk maybe for them to take in a what might be a close.

Bruce D. Broussard
CEO, Humana Inc

Election year.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

You know, election year.

Bruce D. Broussard
CEO, Humana Inc

Yeah.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

I'm with you on the bull case, for sure and probably on the base case, too. So I guess the question is, how is that argument gaining any purchase yet or.

Bruce D. Broussard
CEO, Humana Inc

Yeah. We just filed our comments on Friday.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Okay.

Bruce D. Broussard
CEO, Humana Inc

So we haven't really been engaged with them, but we'll see over the next 30 days.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Gotcha. And then just sticking with advance notice, you know, your, your bridge from 2024 to 2025 is $6 to $10 of earnings improvement, margin improvement. I hate to bring up the bear case. But when I when I kinda look at the near-term bear case, if, if the advance notice holds, which is not our base case and hopefully, it's not, I think the 6-10 would be very, very, you know, challenging given what they've, you know, delivered on the rate. Or, you know, earnings growth at all or material earnings growth look would look to be challenged. Can you comment on, on that? Are you willing to comment on what if, if the rate held, like, what happens to the $6 to $10 bridge?

Susan M. Diamond
CFO, Humana Inc

Yeah. So I think, you know, as we've said, we were very clear about the assumptions that, you know, we relied on when we set the 6-10. And within that range, as we said, you know, the lower end of that range, you know, the things that might ultimately cause you to be at the lower end might be a rate notice that's not quite in line with what we expected or the competitive environment as such where we're taking larger benefit changes and see larger membership impacts as a result. To get to the higher end of the range, you might have to see a slightly favorable rate notice or the competitive environment more level where, say, think of more like flat membership versus membership declines.

Certainly, if we saw no improvement in the final rate notice, that would be a meaningful difference, obviously, relative to what we expected and would certainly concede that it would make the $6 to $10 more challenging. I would argue definitely take the high end of that off the table. We would still work very hard to try to deliver within that. But I think, in all fairness, we'd have to see what that looks like. We did not run every scenario imaginable. So we would have to see ultimately where the rate notice comes out, to the degree it's different, what does that look like, what are the opportunities to optimize the plans underneath. There are still opportunities. So I don't want anyone to think even if it doesn't see any improvement that there's no opportunity for, you know, EPS and earnings improvement. There is.

As we've said, we do have some plans that are not profitable today. A rate notice that's that onerous would make that a bigger number. And so we would certainly look and say at a plan and county level, if there are plans where the path to profitability is just too far into the future and can't you know, and there if there are things underneath, whether it's provider environments, etc., that can't be addressed, then we would look to exit. And that would have sort of no regret me you know, membership implications but the opportunity to improve the earnings profile. And I would just say there are other opportunities if that were really the environment we were working in where, to your point, you're limited by TBC and other real limitations.

I mean, the response to that would be, again, either exit more plans or potentially consider launching new plans that allow you to create a benefit construct that we think is more sustainable. So those are all things we would do. But in fairness, you know, if it really saw no improvement given the magnitude of difference, we couldn't say with certainty what that might mean in terms of 2025 at this point. We'd have to do the work. And then certainly, post-bids would be providing you guys with an update on what you can expect. But our hope is that we will minimally see the level of change we've historically seen, if not more, given the environment, that allows to be much closer to what we assumed.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Agreed. Fingers crossed on that. Last question would just be, “2025 technical notice had this change in the broker compensation limits where they would, you know, apply this measure of fair market value of administrative services to the brokers but not to the FMOs and the TPMOs? And I've read your comments on this, excuse me, to CMS. I've read everybody's comments on this. I think there's hundreds and hundreds of pages of comments on this. My instinct is, this gets pushed off and not finalized. It seems very vague what actually exactly was proposed. And anyway, do you share that view? Do you have a thought that maybe, you know, they won't be in position to finalize that in April? Or what do you think the implications would be?”

Bruce D. Broussard
CEO, Humana Inc

I don't know. I don't know if they'd be in a position or not. It's just a question of do they wanna take it on.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Yeah.

Bruce D. Broussard
CEO, Humana Inc

Right now it needs to be done because your wording is vague, really creates a lot of challenges in how you pay the brokers and what are administrative fees and what goes to the broker. And we would like to see clarity around this because we do.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Yeah.

Bruce D. Broussard
CEO, Humana Inc

We do find that the channel is very valuable for members to fully understand what their needs are and to be able to educate them on that. And we wanna find the right incentives that provide the broker that because at the end of the day, it's really the broker that does this, and that and to create an even playing field that people are not interpreting it from one to another way of, of approach. And therefore, that you create this disconnect in the industry where you have, some players paying a lot of administrative fees, which is what we see today.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Yeah.

Bruce D. Broussard
CEO, Humana Inc

While others like ourselves and even United are paying much less administrative fees. So you create this odd incentives that we're not competing on the same in the same way. Therefore, it also creates misincentives.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Got it. Are we are we at time or overtime?

Bruce D. Broussard
CEO, Humana Inc

It's your overtime, but.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Two minutes. Oh, we're overtime. Okay.

Bruce D. Broussard
CEO, Humana Inc

That's what the red light.

Gary Taylor
Managing Director and Senior Equity Research Analyst, TD Cowen

Thanks.

Bruce D. Broussard
CEO, Humana Inc

That's what the red light means. I don't pay a lot of attention to it, 'cause we started early. That's why. It's only 9:40 A.M. But, class dismissed.

Powered by