Updated - PLAN YEAR 2026 Individual, On-Marketplace Rate Filings

Hugh McDonald SECRETARY OF COMMERCE * AID ARKANSAS INSURANCE DEPARTMENT * * Bulletin No. 4A-2025 Alan McClain COMMISSIONER, ARKANSAS INSURANCE DEPARTMENT TO: All Licensed Health Insurers, Health Maintenance Organizations (HMOs), Fraternal Benefit Societies, Hospital Medical Services Corporations, and other Interested Parties FROM: Arkansas Insurance Department SUBJECT: Updated: Plan Year 2026 Individual, On-Marketplace Rate Filings DATE: May 14,2025 This Bulletin 4A-2025 revises some of the guidance in AID's Bulletin 4-2025 due to two (2) Bulletins issued by the Centers for Medicare and Medicaid Services (CMS) on May 2, 2025. Any provisions of Bulletin 4-2025 not specifically amended remain in full force and effect. Two Sets of Rates Required In the Bulletin entitled "Plan Year 2026 Individual Market Rate Filing Instructions," CMS provides direction to states and carriers regarding the submission of rate filing justifications for plan year 2026 for single risk pool coverage. As a result, AID is amending the guidance provided in Section 1 of Bulletin 4-2025. AID still recommends carriers issue two sets of rates, but, like CMS, AID no longer recommends that the second-rate filing assume the expanded tax credits under the American Rescue Plan Act of 2021(ARPA) will be extended through 12/31/2026. Instead, AID now recommends that carriers follow CMS's guidance and prepare a second-rate filing justification submission based on the following assumptions: (1) Congress appropriates funds to make cost-share reduction (CSR) payments to issuers; and (2) The enhanced premium tax credits under the ARPA and Inflation Reduction Act of 2022 (IRA) expire at the end of 2025. As stated in Bulletin 4-2025, all documentation necessary to support the alternate rates, including a Unified Rate Review Template (URRT) and any rate filing exhibits needed to support the alternate rates should be included. These documents should be included within the "Supporting Documentation" tab of SERFF under a component header titled "Appendix - Alternative Arkansas Department of Commerce Arkansas Insurance Department 1 Commerce Way, Suite 102 • Little Rock, AR 72202 INSURANCE.ARKANSAS.GOV 1 Submission." These documents supporting the alternate rates should be clearly identified in the file name (e.g., "URRT for Alternate Rates Assuming Extension of PTC Enhancements") and should be clearly and prominently labeled on the document to avoid confusion. Off-Exchange-Only Plans Without CSR Loading As described in Bulletin 4-2025, AID calculated the CSR load for On-Marketplace Silver plans to be 1.46. As CMS noted in the Bulletin entitled "Offering of off-Exchange-only plans without 'CSR loading," this load can leave unsubsidized enrollees purchasing coverage both on and off the exchange with silver plan premiums much higher than those plan premiums would have been without the load. AID requires issuers to offer and market plans in the individual market that will be available exclusively off-Exchange and will not include any CSR load. AID will review all submissions for compliance, reasonableness, and adherence to this guidance. Questions related to this Bulletin may be directed to the Compliance Division at Donna.LamberWArkansas.gov or 501-371-2770. Alan McClain Insurance Commissioner State Of Arkansas 2 r i \c" ILL , cloaS DATE