By Stacey Pogue, Billy Dering, JoAnn Volk, and Kevin Lucia
It’s the beginning of rate review season for state insurance departments. Although most proposed premium rates for 2026 coverage will not be public until the end of July, some state regulators require submissions in May or June and release varying levels of information early in the process. These early rate filings provide an initial look at how insurers are responding to market trends and policy changes.
This year, insurers are setting their rates for 2026 while Congress and the administration weigh the following three policies that are projected to cause premiums to spike and the number of people with Marketplace coverage to plummet:
Any of these policies, explained further in other CHIRblog posts, individually could have a notable impact on premiums for 2026 and beyond. Insurers are facing the possibility that all three changes could be in place before 2026 coverage takes effect, and enormous uncertainty—which can also drive up rates—about which specific provisions will ultimately take effect and when.
The following is a round-up of information released so far by states on proposed rate changes for 2026 individual market coverage and related analysis.
Eye-popping proposed increases for 2026
A few states with earlier rate filing deadlines have released summary information on proposed rate changes in the individual market. Some states have released a weighted statewide average rate increase proposed across all insurers, others have posted average rate changes proposed by each insurer, and some have posted both. As shown in the table below, summary information released by state insurance regulators to date uniformly shows 2026 average rates heading in one direction: up, often substantially. Statewide average proposed increases, where released by the state, all show double-digit rate hikes, ranging from 10% in Oregon to 24% in Rhode Island.
Table: Average Proposed Individual Market Rate Increases, Select States, Plan Year 2026
| State | Statewide Average Proposed Increase | Range | Additional information | |
| Lowest average rate request by carrier | Highest average rate request by carrier | |||
| Connecticut | 17.8% | 5.9% (CTCare off-exchange) | 26.1% (ConnectiCare) | Proposed rates do not include scheduled ePTC expiration, which would increase proposed rates by an additional 3.5% to 6.8% of premium by carrier. |
| 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 rates include scheduled ePTC expiration. If Congress extends ePTC, statewide average proposed rate increase would instead be 7.9% |
| Massachusetts | 13.4% | 9.9% (Fallon) | 16.2% (Boston Medical Center) | |
| Minnesota | — | 7.2% (Quartz) | 26.0% (Medica) | |
| New York | — | 0.9% (EmblemHealth) | 66.4% (UnitedHealthcare Insurance Co) | |
| Oregon | 9.7% | 3.9% (PacificSource) | 12.9% (Kaiser) | |
| Pennsylvania | 19% | — | — | |
| Rhode Island | 23.7% | 21.2% (Neighborhood Health Plan) | 28.9% (BCBS) | Proposed rates include scheduled ePTC expiration, which adds 4.9% to 9.7% of premium by carrier to proposed rate increase. |
| Vermont | — | 6.2% (MVP) | 23.3% (BCBS) | |
| Washington | 21.2% | 9.6% (Regence BlueShield) | 37.3% (United Healthcare) | Proposed rates include scheduled ePTC expiration. If Congress extends ePTC, proposed rate increases could be reduced by as much as 6.4% of premium. |
Note: Average proposed rate change statewide and/or by carrier for 2026 ACA individual market (or merged market, as applicable) coverage as posted by states as of June 23, 2025. See linked source materials for further information.
A few state insurance regulators provided context about the magnitude of the proposed spike in individual market rates for 2026. Rhode Island’s regulator noted the “requested rate increases are the highest in over a decade,” while Maryland’s said they “are the highest since the implementation of Maryland’s reinsurance program in 2019.”
Insurers point to loss of ePTC and uncertainty around federal policy changes
A handful of states also publish the detailed supporting documentation filed by insurers relatively early compared to other states. These documents explain the assumptions used by insurers and their justifications for the types of proposed rate increases shown above. We reviewed* insurer justifications from three of these states, Maryland, Maine, and Vermont, to see how anticipated policy changes and uncertainty around them are impacting proposed rates for 2026.
Expiration of ePTC drives up rates
A variety of factors impact proposed rate changes, including changes to the unit cost of health care services and supplies, utilization, benefits, and the covered population. In addition to these types of factors that commonly drive annual changes, insurers in our sample states universally cited the expiration of ePTC at the end of 2025 as having a key impact on proposed rate increases. As explained in excerpts from filings below, the end of ePTC is expected to create a smaller, sicker risk pool, driving up rates.
- In Maine, Community Health Option proposed a 34% average rate increase. It explains that with the loss of ePTC, enrollment will drop, and they “anticipate the remaining risk pool in 2026 [will] have higher healthcare needs, on average, as healthier consumers are more likely to lapse coverage.”
- In Maryland, Optimum Choice proposed an average rate increase of 18.6%. It pointed to the end of ePTCs driving lower enrollment, and as a result, “[h]ealthier members are expected to leave at a disproportionately higher rate than those with significant healthcare needs, increasing market morbidity in 2026.”
- In Vermont, Blue Cross Blue Shield proposed an average rate increase of 23.3%, which incorporates “an additional increase of 6.6 percent” from the loss of ePTC. The carrier anticipates that the end of ePTC “will shrink the population with coverage and worsen the risk pool, requiring higher premiums for the remaining members.”
- Also in Vermont, MVP proposed a 6.2% average increase and assumes healthy individuals with subsidies will drop coverage when ePTCs expire at twice the rate of other subsidized individuals, leading to a sicker risk pool.
Policy-induced turbulence may further drive up rates or spur insurer exits
As a general rule, state insurance regulators require insurance companies to submit proposed rates that reflect current law. In other words, proposed rates should not attempt to anticipate future changes in law, such as enactment of H.R. 1 or the finalization of the proposed Marketplace Integrity rule.
Therefore, insurers in most states had to set their rates for 2026 amidst significant uncertainty from the shifting federal policy landscape. Some states asked insurers to file more than one set of rates for 2026, reflecting uncertainty over whether ePTC would expire or be extended by Congress and/or whether cost sharing reduction (CSR) payments would remain unfunded. But even with those contingencies, filings for 2026 had caveats hinting at concerns about policy changes that may happen after rates are submitted for regulator review.
- In Maryland, Wellpoint, which proposed an average 8.1% increase, flagged uncertainty about ePTCs and assumptions about CSR payments while cautioning that that, “[f]uture modifications in legislation, regulation and/or court decisions may affect the extent to which the premium rates are neither excessive nor deficient. Wellpoint reserves the right to file revised rates in the event of changes to the regulatory environment in which they were developed.”
- In Maine, Anthem proposed an 18.0% average rate increase. The insurer cautions that “the rates proposed in this submission reflect the regulatory framework and insurer participation in the market as of June 5, 2025. If the regulatory framework or insurer participation in the market changes after this date, proposed rates may no longer be appropriate and should be reevaluated for revision and resubmission.”
- In Vermont, MVP notes that it filed two sets of rates, one with and another without, continued ePTC, but the carrier “reserves the right to modify the submitted rates,” given that eventual PTC changes could differ from both of the modeled scenarios.
- In Maryland, Optimum Choice proposed an average 18.6% rate increase for 2026, and noted that the proposed Marketplace Integrity rule (which was just finalized, a month after this rate filing), “will lead to healthier enrollees leaving the market and an overall worsening of the risk pool.”
Uncertainty about ACA policy shifts can also feed into decisions about whether insurers remain in current markets. Aetna, for example, recently announced it would exit ACA Marketplaces entirely after 2025 due in part to uncertainty over federal ACA policy. This change affects 1 million consumers across 17 states, including Maryland.
- In Maryland, Optimum Choice proposed an average 18.6% rate increase for 2026. After flagging regulatory considerations related to ePTC expiration and CSR payments, the carrier warned,”[t]he submission of these rates does not guarantee that OCI will continue to participate in the individual market in 2026.”
Policies advancing in Congress will have profound effects on the individual market
Most of the states that have released early rate filings operate their own state-based Marketplace and have expanded Medicaid under the Affordable Care Act. Proposed rates are likely to be even higher in states that have not expanded Medicaid. A sobering new report from Wakely predicts “a much smaller and less stable individual market” across all states if Congress enacts H.R. 1 as passed by the House (which incorporates changes proposed in the Marketplace Integrity rule, many of which have now been made final) and fails to extend ePTC. Wakely estimates that individual market enrollment could plummet by 47% to 57% on average, with even larger enrollment losses, up to 64%, in non-Medicaid expansion states. In total, the individual market would lose an estimated 11 million to 14 million enrollees, dropping to low levels not seen “since the early years of the Marketplaces, if not lower.”
As enrollment shrinks, “morbidity” will increase. In other words, people who retain coverage will be sicker and have higher health care needs than those who drop coverage, driving up premiums. The combined impacts of just these policies would cause “large gross premium increases” of 7-12% on average, and far higher average net premium increases for subsidized individuals as premium tax credits shrink.
Insurance regulators in some states are also raising concerns about the totality of impacts of federal policies on the table on premiums and coverage. For example, Maryland Insurance Commissioner Marie Grant noted that while the “significant rate increases” already filed for 2026 reflect the loss of ePTC, “recent actions by Congress have the potential to further lower tax credits for Marylanders to help purchase health coverage and further increase rates in this critical market.”
Takeaway
Early information on proposed individual market rates for 2026 shows widespread and substantial rate increases. Among the many factors driving up rates, some are not business as usual. Instead, insurers are responding to an array of disruptive federal ACA policy changes. Early rate filings clearly reflect the impact of one shoe dropping–the scheduled expiration of ePTC– and also concern about other shoes that may still drop. Insurers anticipate steep declines in enrollment, increases in morbidity among remaining enrollees, and significant premium increases due to federal policy changes. Additionally, the high degree of uncertainty around proposed policies that could take effect by 2026, has prompted caveats by insurers and state regulators that rates could change at any point. With dire projections of smaller, sicker, and more expensive Marketplaces after federal ACA policy changes, we may see other insurers exit the Marketplaces altogether, on the heels of Aetna’s recent announcement. Even with these early filings, the impact of the policy changes is becoming clear – lower enrollment and higher premiums. Continued monitoring of rate filings over the next couple of months will help to reveal the full scope of how much these federal policies will erode the individual health insurance market.
*Authors’ note: Our review of early 2026 individual market rate filings was largely limited to the narratives in the actuarial memoranda that must accompany each rate filing. These memos explain, in lay language, insurers’ past experience, current assumptions, and predictions for the next plan year. The findings summarized in this blog are not necessarily generalizable to the broader universe of individual market rate filings for plan year 2026, nor do they reflect all of the factors underlying rate requests or differences between insurers filing individual market rates in this set of states. The authors thank Norah C. Ludke and Logan DeLeire for their assistance monitoring and documenting insurers’ rate filings.
