On Mar. 14, MO INS issued bulletin re filing dates for plan year 2026.
MO INS issued Bulletin 25-01 in order to provide notice to health carriers of the key filing dates for health benefit plans that will be offered during the 2026 plan year.
Submission deadline for 2026 plan year filing has been moved up, to Jun. 4, 2025.
Health Plan Filing Dates
Congress has not taken action to extend expanded eligibility for Advanced Premium Tax Credits (eAPTCs) enacted with American Rescue Plan, beyond 2025 calendar year.
Expects that carriers will file one set of rates assuming that eAPTCs will expire before 2026 plan year, will not accept rate filing with multiple rates for multiple contingencies.
Filing companies should document the assumptions that would change, and the impact to the rates that would result if the existing eAPTCs were extended for plan year 2026.
MO INS will continue collecting actuarial data and practice that plan-level factors not be based on Affordable care act (ACA) experience re impacts to risk adjustment.
Factors should consider the differences in benefit and utilization due to cost-sharing.
Additionally, MO INS 20-400-13.100 (health insurance rates) addresses the practice of applying Cost Sharing Reduction (CSR) load only to Silver plans sold on the exchange.
Provides consistency in approach re induced demand factors (IDFs) and the CSR load.
Included 2026 plan year filing timeframes for single risk pools (individual and small group), and transitional, grandfathered, student health plans and other benefit plans.
Regulators
MO INS
Entity Types
IB; Ins
Reference
Bul 25-01, 3/14/2025; Citation: MO INS 20-400-13.100;
Functions
Actuarial and Valuation; Compliance; Reporting; Risk; Tax
