PY 2026 Amended Filing Requirements for Medical Plans in the Individual Market ___________________________________

- 1 - STATE OF MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES Bulletin 2025-15-INS In the Matter of PY 2026 Amended Filing Requirements for Medical Plans in the Individual Market ___________________________________/ Issued and entered this 21st day of May 2025 by Anita G. Fox Director This bulletin establishes amended filing requirements for the individual market plan year 2026. This bulletin supersedes Bulletin 2025-08-INS to the extent it conflicts with or supplements Bulletin 2025-08-INS. In all other respects, Bulletin 2025-08-INS continues to apply. Centers for Medicare & Medicaid Services (CMS) issued its Plan Year 2026 Individual Market Rate Filing Instructions bulletin (“CMS Rate Bulletin”) on May 2, 2025, providing additional instructions to states and issuers for PY26 in light of potential Congressional actions that could affect PY26 individual market rates. Accordingly, DIFS has updated guidance to require two sets of rates and rate filing justification documents in the individual market (Primary and Secondary). In addition, DIFS has updated its guidance regarding support in the Actuarial Memorandum for loading rates for unfunded cost-sharing reduction (CSR) payments. PY26 Submission Timelines – Individual Market To allow issuers time to prepare, DIFS is amending the timeline for submission of individual issuers’ Forms, Binder, and Rates for all on- and off-Marketplace plans as follows: • Forms Filing and Binder – May 28, 2025 (as established in Bulletin 2025-08-INS) • Rates Filing (Primary and Secondary) – June 16, 2025 To accommodate the separate timelines, Forms and Rates should be submitted as separate filings. Two Sets of Rates in the Individual Market In response to and consistent with the CMS Rate Bulletin, within the Rates Filing, DIFS requires issuers to submit two sets of rates and rate filing justification documents in the individual market. The two sets, labeled Primary and Secondary, will differ based on the following assumptions: • Primary: Congress continues to not appropriate funds to make CSR payments to issuers, and the enhanced advanced premium tax credits (eAPTC) under the American Rescue Plan Act (ARPA) and Inflation Reduction Act (IRA) expire at the end of 2025. - 2 - Unless DIFS instructs otherwise, the Primary rates and rate filing justifications will represent the issuer’s individual market rate request for PY26 and should be submitted in the Rate Filing in accordance with Bulletin 2025-08-INS. The Rates Table Template and rate filing justifications should be labeled “Primary” on every page and file. • Secondary: Congress appropriates funds to make CSR payments to issuers, and the eAPTC under the ARPA and IRA expire at the end of 2025. Issuers must submit a second set of rates and rate filing justifications in the Rates Filing assuming Congress appropriates CSR payments to issuers and the eAPTC expire at the end of 2025. The Secondary rates and rate filing justifications will be reviewed for statutory compliance and reasonableness. Issuers should be prepared to update the URRT tab and binder documentation at DIFS’ direction should appropriations result consistent with the Secondary assumption. The Rates Table Template and rate filing justifications should be placed in the Supporting Documentation tab of the Form/Rate filing and labeled “Secondary” on every page and file. Consistent with Bulletin 2025-08-INS, issuers should still provide in their Actuarial Memorandum (both Primary and Secondary) the rate change associated with the expiration of the eAPTC and the potential impact should the subsidies be restored, as well as the associated methodology used to determine the rate change and potential impact. Consistent with the CMS Rate Bulletin, issuers that make permitted plan-level adjustments to account for CSR amounts provided to eligible enrollees for which the issuer does not otherwise receive reimbursement must include in the Actuarial Memorandum the actual CSRs that the issuer paid for enrollees for plan year 2024. Any questions regarding this bulletin should be directed to: Department of Insurance and Financial Services Office of Insurance Rates and Forms 530 West Allegan Street, 7th Floor Lansing, Michigan 48933 Toll Free: (877) 999-6442 /s/ _________________________________________ Anita G. Fox Director