The rules would establish an important new tool for reining in rising health insurance premiums. We believe that many consumers will benefit from the increased transparency and oversight of rate increases envisioned in this rule. We recognize that the proposed rule is designed to maintain the traditional role of the states in overseeing health insurance rates. Consumers Union has spent substantial time studying state rate review standards and rate increases, particularly in the individual market. We believe that many aspects of the proposed rule will result in enhanced (and much-needed) scrutiny of certain rate increases. However, we also believe that the rule should provide greater incentives and a pathway for states to improve their rate review processes and for carriers to strive to curb underlying costs and make rates more affordable.