MI| The Michigan Department of Insurance and Financial Services (DIFS) Bulletin 2025-08-INS outlines the 2026 form and rate filing requirements for medical plans offered on- and off-Marketplace, including timelines, documentation standards, and regulatory updates. Issuers must submit all required forms, rates, and supporting documentation through SERFF by May 14, 2025 (small group) or May 28, 2025 (individual), and must account for the likely expiration of enhanced premium tax credits unless federal legislation extends them. Notable updates for Plan Year 2026 include new network adequacy standards (such as a 30-minute travel time for pharmacy providers), stricter plan naming conventions, and requirements for Quality Improvement Strategy filings to address healthcare disparities. Additional guidance covers guaranteed renewability, plan withdrawal protocols, actuarial value calculations, anti-discrimination compliance, and specific coverage mandates for essential health benefits and autism spectrum disorder treatments.
Key Points:
- Issuers must file all forms, rates, and supporting documentation by set deadlines (May 14 for small group, May 28 for individual), using SERFF, and must assume enhanced premium tax credits will not be available for 2026 unless Congress acts.
- New requirements include a 30-minute pharmacy travel time standard for network adequacy, stricter plan naming rules, and enhanced Quality Improvement Strategy filings focusing on reducing healthcare disparities.