Monday, December 1, 2025

Early 2026 Price Filings Present Market Coverage Adjustments Contribute to Eye-Popping Price 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 top of July, some state regulators require submissions in Could or June and launch various ranges of knowledge early within the course of. These early price filings present an preliminary have a look at how insurers are responding to market traits and coverage modifications.

This 12 months, 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 individuals 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 each one three modifications could possibly be in place earlier than 2026 protection takes impact, and massive uncertainty—which may additionally drive up charges—about which particular provisions will finally take impact and when.

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

Eye-popping proposed will increase for 2026

Just a few states with earlier price submitting deadlines have launched abstract info on proposed price modifications within the particular person market. Some states have launched a weighted statewide common price enhance proposed throughout all insurers, others have posted common price modifications proposed by every insurer, and a few have posted each. As proven within the desk under, abstract info launched by state insurance coverage regulators so far uniformly exhibits 2026 common charges heading in a single path: up, usually 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 Price Will increase, Choose States, Plan Yr 2026

State Statewide Common Proposed Enhance 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 embody scheduled ePTC expiration, which might enhance proposed charges by a further 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 embody scheduled ePTC expiration. If Congress extends ePTC, statewide common proposed price enhance would as a substitute 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 embody scheduled ePTC expiration, which provides 4.9% to 9.7% of premium by provider to proposed price enhance.
Vermont 6.2% (MVP) 23.3% (BCBS)  
Washington 21.2% 9.6% (Regence BlueShield) 37.3% (United Healthcare) Proposed charges embody scheduled ePTC expiration. If Congress extends ePTC, proposed price will increase could possibly be diminished by as a lot as 6.4% of premium.

Be aware: 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.

Just a few 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 best in over a decade,” whereas Maryland’s mentioned they “are the best because the implementation of Maryland’s reinsurance program in 2019.”

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

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 varieties 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 modifications and uncertainty round them are impacting proposed charges for 2026.

Expiration of ePTC drives up charges

Quite a lot of components influence proposed price modifications, together with modifications to the unit price of well being care providers and provides, utilization, advantages, and the lined inhabitants. Along with most of these components that generally drive annual modifications, 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 under, the top of ePTC is predicted to create a smaller, sicker danger pool, driving up charges.

  • In Maine, Group Well being Choice proposed a 34% common price enhance. It explains that with the lack of ePTC, enrollment will drop, they usually “anticipate the remaining danger pool in 2026 [will] have larger healthcare wants, on common, as more healthy customers usually tend to lapse protection.”
  •  In Maryland, Optimum Selection proposed a mean price enhance of 18.6%. It pointed to the top of ePTCs driving decrease enrollment, and in consequence, “[h]ealthier members are anticipated to depart at a disproportionately larger price than these with vital healthcare wants, growing market morbidity in 2026.”
  • In Vermont, Blue Cross Blue Defend proposed a mean price enhance of 23.3%, which contains “a further enhance of 6.6 %” from the lack of ePTC. The provider anticipates that the top of ePTC “will shrink the inhabitants with protection and worsen the danger pool, requiring larger premiums for the remaining members.”
  • Additionally in Vermont, MVP proposed a 6.2% common enhance and assumes wholesome people with subsidies will drop protection when ePTCs expire at twice the speed of different backed people, resulting in a sicker danger pool.

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

As a common rule, state insurance coverage regulators require insurance coverage firms to submit proposed charges that mirror present legislation. In different phrases, proposed charges mustn’t try to anticipate future modifications in legislation, akin 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 vital uncertainty from the shifting federal coverage panorama.  Some states requested insurers to file a couple of 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 modifications which will occur after charges are submitted for regulator assessment.

  • In Maryland, Wellpoint, which proposed a mean 8.1% enhance, flagged uncertainty about ePTCs and assumptions about CSR funds whereas cautioning that that, “[f]uture modifications in laws, regulation and/or court docket selections might have an effect on the extent to which the premium charges are neither extreme nor poor. Wellpoint reserves the appropriate to file revised charges within the occasion of modifications to the regulatory surroundings wherein they had been developed.”
  • In Maine, Anthem proposed an 18.0% common price enhance. 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 modifications after this date, proposed charges might not be applicable 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 appropriate to change the submitted charges,” provided that eventual PTC modifications may differ from each of the modeled situations.
  • In Maryland, Optimum Selection proposed a mean 18.6% price enhance 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 total worsening of the danger pool.”

Uncertainty about ACA coverage shifts may feed into selections about whether or not insurers stay in present markets. Aetna, for instance, just lately introduced it might exit ACA Marketplaces fully after 2025 due partially to uncertainty over federal ACA coverage. This transformation impacts 1 million customers throughout 17 states, together with Maryland.

  • In Maryland, Optimum Selection proposed a mean 18.6% price enhance for 2026. After flagging regulatory issues 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 could have profound results on the person market

A lot of the states which have launched early price filings function their very own state-based Market and have expanded Medicaid below the Reasonably priced Care Act. Proposed charges are prone to be even larger 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 contains modifications proposed within the Market Integrity rule, lots of which have now been made ultimate) 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 growth states. In complete, the person market would lose an estimated 11 million to 14 million enrollees, dropping to low ranges not seen “because the early years of the Marketplaces, if not decrease.”

As enrollment shrinks, “morbidity” will enhance. In different phrases, individuals who retain protection can be sicker and have larger 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 larger 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 “vital 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 enhance 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 components driving up charges, some should not enterprise as regular. As a substitute, insurers are responding to an array of disruptive federal ACA coverage modifications. Early price filings clearly mirror the influence of 1 shoe dropping–the scheduled expiration of ePTC– and likewise concern about different sneakers which will nonetheless drop. Insurers anticipate steep declines in enrollment, will increase in morbidity amongst remaining enrollees, and vital premium will increase resulting from federal coverage modifications. Moreover, the excessive diploma of uncertainty round proposed insurance policies that might 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 dearer Marketplaces after federal ACA coverage modifications, 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 modifications is turning into clear – decrease enrollment and better premiums. Continued monitoring of price filings over the subsequent 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’ observe: 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 subsequent plan 12 months. The findings summarized on this weblog should not essentially generalizable to the broader universe of particular person market price filings for plan 12 months 2026, nor do they mirror the entire components 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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