By Stacey Pogue, Billy Dering, JoAnn Volk, and Kevin Lucia
It’s the start of charge evaluate season for state insurance coverage departments. Though most proposed premium charges for 2026 protection is not going to be public till the top of July, some state regulators require submissions in Might or June and launch various ranges of data early within the course of. These early charge filings present an preliminary have a look at how insurers are responding to market traits and coverage modifications.
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 impression on premiums for 2026 and past. Insurers are going through the likelihood that every one three modifications might be in place earlier than 2026 protection takes impact, and large uncertainty—which might additionally drive up charges—about which particular provisions will in the end take impact and when.
The next is a round-up of data launched thus far by states on proposed charge modifications for 2026 particular person market protection and associated evaluation.
Eye-popping proposed will increase for 2026
A number of states with earlier charge submitting deadlines have launched abstract info on proposed charge modifications within the particular person market. Some states have launched a weighted statewide common charge improve proposed throughout all insurers, others have posted common charge 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 to this point 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 charge hikes, starting from 10% in Oregon to 24% in Rhode Island.
Desk: Common Proposed Particular person Market Charge Will increase, Choose States, Plan Yr 2026
| State | Statewide Common Proposed Enhance | Vary | Extra info | |
| Lowest common charge request by service | Highest common charge request by service | |||
| Connecticut | 17.8% | 5.9% (CTCare off-exchange) | 26.1% (ConnectiCare) | Proposed charges don’t embody scheduled ePTC expiration, which might improve proposed charges by an extra 3.5% to six.8% of premium by service. |
| 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 charge 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 embody scheduled ePTC expiration, which provides 4.9% to 9.7% of premium by service to proposed charge improve. |
| 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 charge will increase might be lowered by as a lot as 6.4% of premium. |
Be aware: Common proposed charge change statewide and/or by service 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 offered context concerning the magnitude of the proposed spike in particular person market charges for 2026. Rhode Island’s regulator famous the “requested charge 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 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 charge 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
A wide range of elements impression proposed charge modifications, together with modifications to the unit price of well being care providers and provides, utilization, advantages, and the coated inhabitants. Along with a majority of these elements 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 impression on proposed charge 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 Possibility proposed a 34% common charge improve. 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 shoppers usually tend to lapse protection.”
- In Maryland, Optimum Selection proposed a median charge improve 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 charge than these with important healthcare wants, growing market morbidity in 2026.”
- In Vermont, Blue Cross Blue Defend proposed a median charge improve of 23.3%, which includes “an extra improve of 6.6 p.c” from the lack of ePTC. The service 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 improve and assumes wholesome people with subsidies will drop protection when ePTCs expire at twice the speed of different sponsored people, resulting in a sicker danger pool.
Coverage-induced turbulence might additional drive up charges or spur insurer exits
As a normal rule, state insurance coverage regulators require insurance coverage corporations to submit proposed charges that replicate present legislation. In different phrases, proposed charges shouldn’t try and anticipate future modifications in legislation, equivalent 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 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 issues about coverage modifications that will occur after charges are submitted for regulator evaluate.
- 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 courtroom selections might 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 modifications to the regulatory setting by which they have been developed.”
- In Maine, Anthem proposed an 18.0% common charge improve. The insurer cautions that “the charges proposed on this submission replicate the regulatory framework and insurer participation available in the market as of June 5, 2025. If the regulatory framework or insurer participation available in the market modifications after this date, proposed charges might now not be acceptable and needs 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 service “reserves the proper to switch the submitted charges,” on condition that eventual PTC modifications may differ from each of the modeled situations.
- In Maryland, Optimum Selection proposed a median 18.6% charge improve for 2026, and famous that the proposed Market Integrity rule (which was simply finalized, a month after this charge submitting), “will result in more healthy enrollees leaving the market and an total worsening of the danger pool.”
Uncertainty about ACA coverage shifts also can feed into selections about whether or not insurers stay in present markets. Aetna, for instance, just lately introduced it could exit ACA Marketplaces fully after 2025 due partly to uncertainty over federal ACA coverage. This modification impacts 1 million shoppers throughout 17 states, together with Maryland.
- In Maryland, Optimum Selection proposed a median 18.6% charge improve for 2026. After flagging regulatory issues associated to ePTC expiration and CSR funds, the service 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 charge filings function their very own state-based Market and have expanded Medicaid below the Inexpensive 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 steady particular person market” throughout all states if Congress enacts H.R. 1 as handed by the Home (which includes modifications proposed within the Market Integrity rule, a lot of which have now been made last) 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 shall 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 “massive gross premium will increase” of 7-12% on common, and much larger common web premium will increase for sponsored people as premium tax credit shrink.
Insurance coverage regulators in some states are additionally elevating issues concerning 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 charge will increase” already filed for 2026 replicate the lack of ePTC, “current 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 crucial market.”
Takeaway
Early info on proposed particular person market charges for 2026 exhibits widespread and substantial charge will increase. Among the many many elements driving up charges, some are usually not enterprise as typical. As a substitute, insurers are responding to an array of disruptive federal ACA coverage modifications. Early charge filings clearly replicate the impression of 1 shoe dropping–the scheduled expiration of ePTC– and in addition concern about different sneakers that will nonetheless drop. Insurers anticipate steep declines in enrollment, will increase in morbidity amongst remaining enrollees, and important premium will increase because of 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 current announcement. Even with these early filings, the impression of the coverage modifications is turning into clear – decrease enrollment and better premiums. Continued monitoring of charge filings over the subsequent couple of months will assist to disclose the total scope of how a lot these federal insurance policies will erode the person medical insurance market.
*Authors’ word: Our evaluate of early 2026 particular person market charge filings was largely restricted to the narratives within the actuarial memoranda that should accompany every charge submitting. These memos clarify, in lay language, insurers’ previous expertise, present assumptions, and predictions for the subsequent plan yr. The findings summarized on this weblog are usually not essentially generalizable to the broader universe of particular person market charge filings for plan yr 2026, nor do they replicate the entire elements underlying charge 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’ charge filings.
