State of Tennessee Department of Commerce and Insurance  (TDCI) investigated the rates charged by the private Medicare exchange (PME) used by TVA retirees.  TDCI confirmed that some rates charged by the PME were significantly higher than purchasing the same Medigap Plan (F, G, etc.) directly from the same insurers.

TDCI stated that the higher rates were due to the PME's use of "separate legal entities" and their different "cost structures".  TDCI did not audit the actual rates to determine if they were properly developed and supported in accordance with generally accepted ratemaking standards.