MO| Missouri Insurance Bulletin 26-11 directs health carriers to revise 2027 health-plan form and rate filings after the federal court’s July 16, 2026 stay in City of Columbus v. Kennedy and subsequent CMS guidance affecting standardized and non-standardized plan requirements. Because CMS enforces ACA market reforms in Missouri while the Department conducts effective rate review, carriers must submit limited, court-order-related revisions promptly through SERFF and file applicable form updates with both the Missouri Department of Commerce and Insurance and CMS.
- Required rate support: Carriers must provide updated affected URRT documents, a redlined actuarial memorandum and concise rationale, an Excel Rate Table Template, AV Calculator screenshots, an updated AV and Cost Sharing Design by Plan template, and a limiting attestation.
- Form filings: Required standardized-plan form revisions were due August 12, 2026. Closed filings require an emailed reopening request; open filings require a Note to Reviewer. Revised forms, redlines, updated supporting documents, a Statement of Variability, and an attestation limiting changes to those required by the court order must be included.
- Rate filings: Revisions were due by noon Central Time on August 17, 2026, to support final rate determinations by August 28. Changes may address only required compliance revisions and immediate downstream effects.