On Apr. 15, MT INS issued memo re federally facilitated exchange.
MT INS issued advisory re 2026 filing requirements, qualified health plan certification.
INS Commissioner will perform the required plan management functions for issuers choosing to participate in Federally Facilitated Exchange (FFE) in 2026 with exceptions.
Follows CMS 2025 publication of 2026 benefit, payment parameters, see #229015.
Also follows CMS Mar. 2025 proposal on health Marketplace safeguards, see #246608.
MT INS Filing Information
Binder, form and network information is due by May 14, 2025, rate filings are due between May 14-Jun. 6, 2025, initial rate transfer is due to CMS by Jun. 11, 2025.
Final day for issuers to make changes to binder, form and rate will be Jul. 30, 2025.
Additionally, the final deadline for the CMS binder is on Aug. 13, 2025.
Additional Required Information
Unified Rate Review Template (URRT), instructions released and due for 2026 filings.
CMS also released a new actuarial value (AV) calculator and methodology for 2026.
MT INS requires issuers to file one set of rates assuming that Expanded Eligibility Advanced Premium Tax Credits (eAPTCs) will expire, and may provide future guidance.
Also included data on the defrayal of state benefits, plan options, reporting of medical loss ratio and rebate calculations, payment threshold as well as reducing cost-sharing.
The 2026 Final Rule notes that there is no change other than stating that CMS is continuing to conduct an adverse tiering review to assess certain medical conditions.
Addresses network adequacy, community providers, method of employee counting, marketplace integrity, health/stand alone dental plan, large group INS requirements.
Deadlines
Network data, forms, and binders, documents with required templates for coverage that will be issued on/after Jan. 1, 2026, must be filed no later than May 14, 2025.
Corrections to rate, network data, form, binder filings to be finalized by Jul. 30, 2025.
Rate filings accepted from May 14 - Jun. 6, rate increases published before Aug. 13.
Regulators
MT INS
Entity Types
Ins
Reference
Adv, 4/15/2025
Functions
Actuarial and Valuation; Compliance; Financial; Legal; Record Retention; Reporting
