MT| Montana’s Commissioner of Securities and Insurance issued a Third Addendum on August 5, 2026 to its April 22, 2026 Advisory Memorandum governing ACA form, rate, and network adequacy filings for policy year 2027, prompted by the July 16, 2026 federal court order in City of Columbus v. Kennedy (D. Md., No. 1:26-cv-02215) that stayed key provisions of CMS’s 2027 Final Notice of Benefit and Payment Parameters — namely the expanded out-of-pocket maximums for individual bronze and catastrophic plans, the broadened catastrophic plan eligibility, and the elimination of standardized plan requirements and non-standardized plan limits. Because issuers and states must now revert to the prior regulations for those stayed provisions, and because CMS pushed its QHP Application change deadline from August 12 to August 20, 2026, CSI is directing Montana issuers to submit responsive SERFF form and rate filing updates by August 10, 2026, limited strictly to four corrective actions: bringing non-compliant bronze OOP limits into line with 45 CFR §156.130, restoring catastrophic plans to prior eligibility rules, filing standardized individual plans per CMS’s August 4, 2026 guidance, and withdrawing excess non-standardized plans or submitting the required attestations — with filings for unaffected plans expressly not accepted.
Click here to see MT August 5, 2026 Advisory Memorandum (3rd Update)