As health insurers begin to file their 2019 rate requests for Affordable Care Act (ACA) exchanges, they are sending clear signals that recent legislative and regulatory actions will factor prominently into their calculations.

Cigna Corp. requested an average 15% increase in Virginia, citing issues including the elimination of the individual mandate penalty and anticipated changes regarding short-term health plans and association health plans as justification for the increase.

CareFirst BlueCross BlueShield filed an average rate increase of 18.5% for its CareFirst BlueChoice HMO plans in Maryland and a 91.4% hike for its PPO plans there. In Virginia, the insurer is seeking an average 26.6% hike for its CareFirst BlueChoice plans and a 64.3% increase for plans offered by subsidiary Group Hospitalization and Medical Services, Inc.

Cori Uccello, a senior health fellow at the American Academy of Actuaries, says that how insurers view the effects of policy changes will be a “major driver” of their premium requests for ACA exchange products.

She adds that if some states opt to impose restrictions on non-ACA-compliant plans, insurers’ proposals could vary throughout the country. Another factor that could lead to geographic variation in premiums is state-based reinsurance programs. States that have such programs “could see, all else [being] equal, lower rates,” Uccello says.

In a note to investors after the Virginia and Maryland rate filings, Citi analyst Ralph Giacobbe wrote that “it is expected that these steep hikes will continue across the country and particularly in rural areas.” Yet these rates are still far from final.