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Friday, June 27, 2025

Early 2026 Charge Filings Present Market Coverage Adjustments Contribute to Eye-Popping Charge Will increase



By Stacey Pogue, Billy Dering, JoAnn Volk, and Kevin Lucia

It’s the start of price assessment season for state insurance coverage departments. Though most proposed premium charges for 2026 protection won’t be public till the tip of July, some state regulators require submissions in Might or June and launch various ranges of knowledge early within the course of. These early price filings present an preliminary take a look at how insurers are responding to market developments and coverage adjustments.

This yr, insurers are setting their charges for 2026 whereas Congress and the administration weigh the next three insurance policies that are projected to trigger premiums to spike and the variety of folks with Market protection to plummet:

Any of those insurance policies, defined additional in different CHIRblog posts, individually may have a notable influence on premiums for 2026 and past. Insurers are dealing with the likelihood that every one three adjustments could possibly be in place earlier than 2026 protection takes impact, and large uncertainty—which may additionally drive up charges—about which particular provisions will in the end take impact and when.

The next is a round-up of knowledge launched to date by states on proposed price adjustments for 2026 particular person market protection and associated evaluation.

Eye-popping proposed will increase for 2026

A number of states with earlier price submitting deadlines have launched abstract info on proposed price adjustments within the particular person market. Some states have launched a weighted statewide common price improve proposed throughout all insurers, others have posted common price adjustments proposed by every insurer, and a few have posted each. As proven within the desk beneath, abstract info launched by state insurance coverage regulators up to now uniformly exhibits 2026 common charges heading in a single route: up, typically considerably.  Statewide common proposed will increase, the place launched by the state, all present double-digit price hikes, starting from 10% in Oregon to 24% in Rhode Island.

Desk: Common Proposed Particular person Market Charge Will increase, Choose States, Plan 12 months 2026

State Statewide Common Proposed Improve Vary Further info
Lowest common price request by provider Highest common price request by provider
Connecticut 17.8% 5.9% (CTCare off-exchange) 26.1% (ConnectiCare) Proposed charges don’t embrace scheduled ePTC expiration, which might improve proposed charges by an extra 3.5% to six.8% of premium by provider.
Illinois 0.2% (Oscar) 27.0% (BCBS)  
Iowa 6.6% (Oscar) 26.8% (Medica)  
Maryland 17.1% 8.1% (Wellpoint) 18.7% (CareFirst BlueChoice) Proposed charges embrace scheduled ePTC expiration. If Congress extends ePTC, statewide common proposed price improve would as an alternative be 7.9%
Massachusetts 13.4% 9.9% (Fallon) 16.2% (Boston Medical Heart)  
Minnesota 7.2% (Quartz) 26.0% (Medica)  
New York 0.9% (EmblemHealth) 66.4% (UnitedHealthcare Insurance coverage Co)  
Oregon 9.7% 3.9% (PacificSource) 12.9% (Kaiser)  
Pennsylvania 19%  
Rhode Island 23.7% 21.2% (Neighborhood Well being Plan) 28.9% (BCBS) Proposed charges embrace scheduled ePTC expiration, which provides 4.9% to 9.7% of premium by provider to proposed price improve.
Vermont 6.2% (MVP) 23.3% (BCBS)  
Washington 21.2% 9.6% (Regence BlueShield) 37.3% (United Healthcare) Proposed charges embrace scheduled ePTC expiration. If Congress extends ePTC, proposed price will increase could possibly be diminished by as a lot as 6.4% of premium.

Notice: Common proposed price change statewide and/or by provider for 2026 ACA particular person market (or merged market, as relevant) protection as posted by states as of June 23, 2025. See linked supply supplies for additional info.

A number of state insurance coverage regulators supplied context in regards to the magnitude of the proposed spike in particular person market charges for 2026. Rhode Island’s regulator famous the “requested price will increase are the very best in over a decade,” whereas Maryland’s mentioned they “are the very best for the reason that implementation of Maryland’s reinsurance program in 2019.”

Insurers level to lack of ePTC and uncertainty round federal coverage adjustments

A handful of states additionally publish the detailed supporting documentation filed by insurers comparatively early in comparison with different states. These paperwork clarify the assumptions utilized by insurers and their justifications for the forms of proposed price will increase proven above. We reviewed* insurer justifications from three of those states, Maryland, Maine, and Vermont, to see how anticipated coverage adjustments and uncertainty round them are impacting proposed charges for 2026.

Expiration of ePTC drives up charges

Quite a lot of elements influence proposed price adjustments, together with adjustments to the unit price of well being care companies and provides, utilization, advantages, and the coated inhabitants. Along with these kinds of elements that generally drive annual adjustments, insurers in our pattern states universally cited the expiration of ePTC on the finish of 2025 as having a key influence on proposed price will increase. As defined in excerpts from filings beneath, the tip of ePTC is anticipated to create a smaller, sicker threat pool, driving up charges.

  • In Maine, Neighborhood Well being Choice proposed a 34% common price improve. It explains that with the lack of ePTC, enrollment will drop, they usually “anticipate the remaining threat pool in 2026 [will] have increased healthcare wants, on common, as more healthy shoppers usually tend to lapse protection.”
  •  In Maryland, Optimum Selection proposed a median price improve of 18.6%. It pointed to the tip of ePTCs driving decrease enrollment, and consequently, “[h]ealthier members are anticipated to depart at a disproportionately increased price than these with important healthcare wants, growing market morbidity in 2026.”
  • In Vermont, Blue Cross Blue Protect proposed a median price improve of 23.3%, which includes “an extra improve of 6.6 p.c” from the lack of ePTC. The provider anticipates that the tip of ePTC “will shrink the inhabitants with protection and worsen the chance pool, requiring increased premiums for the remaining members.”
  • Additionally in Vermont, MVP proposed a 6.2% common improve and assumes wholesome people with subsidies will drop protection when ePTCs expire at twice the speed of different backed people, resulting in a sicker threat pool.

Coverage-induced turbulence could additional drive up charges or spur insurer exits

As a basic rule, state insurance coverage regulators require insurance coverage corporations to submit proposed charges that mirror present regulation. In different phrases, proposed charges mustn’t try and anticipate future adjustments in regulation, similar to enactment of H.R. 1 or the finalization of the proposed Market Integrity rule.

Due to this fact, insurers in most states needed to set their charges for 2026 amidst important uncertainty from the shifting federal coverage panorama.  Some states requested insurers to file multiple set of charges for 2026, reflecting uncertainty over whether or not ePTC would expire or be prolonged by Congress and/or whether or not cost sharing discount (CSR) funds would stay unfunded. However even with these contingencies, filings for 2026 had caveats hinting at considerations about coverage adjustments which will occur after charges are submitted for regulator assessment.

  • In Maryland, Wellpoint, which proposed a median 8.1% improve, flagged uncertainty about ePTCs and assumptions about CSR funds whereas cautioning that that, “[f]uture modifications in laws, regulation and/or court docket choices could have an effect on the extent to which the premium charges are neither extreme nor poor. Wellpoint reserves the proper to file revised charges within the occasion of adjustments to the regulatory surroundings wherein they had been developed.”
  • In Maine, Anthem proposed an 18.0% common price improve. The insurer cautions that “the charges proposed on this submission mirror the regulatory framework and insurer participation out there as of June 5, 2025. If the regulatory framework or insurer participation out there adjustments after this date, proposed charges could not be acceptable and ought to be reevaluated for revision and resubmission.”
  • In Vermont, MVP notes that it filed two units of charges, one with and one other with out, continued ePTC, however the provider “reserves the proper to change the submitted charges,” provided that eventual PTC adjustments may differ from each of the modeled eventualities.
  • In Maryland, Optimum Selection proposed a median 18.6% price improve for 2026, and famous that the proposed Market Integrity rule (which was simply finalized, a month after this price submitting), “will result in more healthy enrollees leaving the market and an general worsening of the chance pool.”

Uncertainty about ACA coverage shifts also can feed into choices about whether or not insurers stay in present markets. Aetna, for instance, just lately introduced it will exit ACA Marketplaces fully after 2025 due partly to uncertainty over federal ACA coverage. This variation impacts 1 million shoppers throughout 17 states, together with Maryland.

  • In Maryland, Optimum Selection proposed a median 18.6% price improve for 2026. After flagging regulatory concerns associated to ePTC expiration and CSR funds, the provider warned,”[t]he submission of those charges doesn’t assure that OCI will proceed to take part within the particular person market in 2026.”

Insurance policies advancing in Congress can have profound results on the person market

Many of the states which have launched early price filings function their very own state-based Market and have expanded Medicaid underneath the Inexpensive Care Act. Proposed charges are prone to be even increased in states that haven’t expanded Medicaid. A sobering new report from Wakely predicts “a a lot smaller and fewer secure particular person market” throughout all states if Congress enacts H.R. 1 as handed by the Home (which includes adjustments proposed within the Market Integrity rule, a lot of which have now been made remaining) and fails to increase ePTC. Wakely estimates that particular person market enrollment may plummet by 47% to 57% on common, with even bigger enrollment losses, as much as 64%, in non-Medicaid enlargement states. In complete, the person market would lose an estimated 11 million to 14 million enrollees, dropping to low ranges not seen “for the reason that early years of the Marketplaces, if not decrease.”

As enrollment shrinks, “morbidity” will improve. In different phrases, individuals who retain protection will probably be sicker and have increased well being care wants than those that drop protection, driving up premiums. The mixed impacts of simply these insurance policies would trigger “giant gross premium will increase” of 7-12% on common, and much increased common web premium will increase for backed people as premium tax credit shrink. 

Insurance coverage regulators in some states are additionally elevating considerations in regards to the totality of impacts of federal  insurance policies on the desk on premiums and protection. For instance, Maryland Insurance coverage Commissioner Marie Grant famous that whereas the “important price will increase” already filed for 2026 mirror the lack of ePTC, “latest actions by Congress have the potential to additional decrease tax credit for Marylanders to assist buy well being protection and additional improve charges on this vital market.”

Takeaway

Early info on proposed particular person market charges for 2026 exhibits widespread and substantial price will increase. Among the many many elements driving up charges, some are usually not enterprise as standard. As a substitute, insurers are responding to an array of disruptive federal ACA coverage adjustments. Early price filings clearly mirror the influence of 1 shoe dropping–the scheduled expiration of ePTC– and in addition concern about different sneakers which will nonetheless drop. Insurers anticipate steep declines in enrollment, will increase in morbidity amongst remaining enrollees, and important premium will increase as a consequence of federal coverage adjustments. Moreover, the excessive diploma of uncertainty round proposed insurance policies that would take impact by 2026, has prompted caveats by insurers and state regulators that charges may change at any level. With dire projections of smaller, sicker, and costlier Marketplaces after federal ACA coverage adjustments, we might even see different insurers exit the Marketplaces altogether, on the heels of Aetna’s latest announcement. Even with these early filings, the influence of the coverage adjustments is changing into clear – decrease enrollment and better premiums. Continued monitoring of price filings over the following couple of months will assist to disclose the complete scope of how a lot these federal insurance policies will erode the person medical health insurance market.

*Authors’ word: Our assessment of early 2026 particular person market price filings was largely restricted to the narratives within the actuarial memoranda that should accompany every price submitting. These memos clarify, in lay language, insurers’ previous expertise, present assumptions, and predictions for the following plan yr. The findings summarized on this weblog are usually not essentially generalizable to the broader universe of particular person market price filings for plan yr 2026, nor do they mirror the entire elements underlying price requests or variations between insurers submitting particular person market charges on this set of states. The authors thank Norah C. Ludke and Logan DeLeire for his or her help monitoring and documenting insurers’ price filings.

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