Judging by the most popular posts on our blog in 2025, people were searching for more information about key legislative and regulatory actions. Whether that be at the federal level with the One Big Beautiful Bill Act and potential return of Cost Sharing Reductions (CSRs), or at the state level with the New Mexico “Medicaid for All” bill or California SB 363, regulatory and legislative actions proved to be our most read content.
2025 was also the year that tariffs dominated the news, with our post about their impact on health insurance rates also garnering the fifth-most views among blog posts. Lastly, Q1 Health Insurance company earnings also proved to be a popular topic as insurers faced mounting headwinds in 2025.
Below is an overview of our top 7 posts in 2025:
1. 2026 Health Insurance Rate Filings: Early Signs Point to High Rate Increases
This post examined preliminary health insurance filings across multiple states, highlighting a national trend of increasing insurance rates.
Preliminary 2026 health insurance rate filings across multiple states, including New York, Washington, Maryland, and Vermont, indicated significant premium hikes for individual and small group markets. In New York, the average weighted increase exceeded 13% in the individual market. The small group market increase was nearly 24%. Similarly, Washington saw a 21.2% average weighted increase in the individual market. The primary drivers cited by insurers across these states are the overall rising cost of healthcare services and equipment, including high-cost weight-loss medications, as well as a general increase in utilization and demand for care.
A major non-medical driver for the increases is the potential expiration of enhanced federal Premium Tax Credits (APTCs). Insurers in Maryland and Vermont specifically noted that if Congress fails to renew these subsidies, the average individual market rate increase would be substantially higher. This increase reflects the expected exit of healthier enrollees and the resulting worsening of market morbidity. In New York, regulatory factors like state taxes, assessments, and new mandates also contribute to the rate requests.
The blog post highlights a significant disparity in New York. Small group premiums increased faster than individual market premiums due to the Federal Risk Adjustment Program. Some large carriers in the individual market anticipate receiving funds from this program (thereby decreasing their proposed rates). However, many small group carriers expect to pay into the program. That will lead to a much higher requested average increase for that segment. The data emphasizes that administrative costs, financial losses from prior years, and the need to maintain statutory reserves are also factors contributing to the upward pressure on premiums across all markets.
2. Medicaid for All? A Look at the New Mexico Medicaid Forward Plan
This post examines New Mexico’s push for so-called “Medicaid for All.” New Mexico’s Medicaid Forward Plan represents a novel approach to expand healthcare coverage, aiming to effectively create a “Medicaid for All” option for residents. The proposal extends Medicaid eligibility to most New Mexicans under age 65. It would remove income requirements for individuals above 133% of the Federal Poverty Level (FPL). Doing so allows them to buy into the program with premiums and cost-sharing based on a sliding scale. The total member financial responsibility (premiums plus out-of-pocket costs) would not exceed 5% of a family’s income. The program would utilize the state’s standard Federal Medical Assistance Percentage (FMAP) for federal matching funds.
Proponents project substantial financial benefits for New Mexico households. Estimates show that overall healthcare spending could decrease by 28.3% to 37.9%, saving up to $1.2 billion each year. Lower-income families would experience the greatest reductions in costs. However, the plan is expected to significantly impact the state’s health insurance marketplace, BeWell. Enrollment in the state exchange could fall up to 89% as individuals shift to the more affordable Medicaid Forward option. It could also reduce enrollment in employer-sponsored insurance (ESI) by up to 26%. That decrease could potentially save large and small employers hundreds of millions in premium contributions. Those savings could then be passed on to workers as higher wages.
The New Mexico Health Care Authority (HCA) would administer the implementation. The HCA would begin phasing in coverage by January 1, 2028. It would likely utilize Managed Care Organizations (MCOs). While the plan offers broad coverage expansion, certain groups remain ineligible. Those include individuals over 65, those already eligible for existing Medicaid, individuals eligible for Medicare, and people with “unsatisfactory immigration status.” The transition also entails significant administrative costs related to scaling up state capacity. Costs include staffing, new procurements, and enhancements or replacements for IT systems.
3. ICHRA Changes in Budget Bill: Codification, Cafeteria Plans, Small Business Credit
The blog post discusses potential changes to Individual Coverage Health Reimbursement Arrangements (ICHRAs) included in a proposed budget reconciliation bill, informally titled “The One, Big, Beautiful Bill.” ICHRAs, which are employer-funded benefits employees use to purchase individual health insurance, have experienced rapid growth since their introduction in 2020. Large employers and companies not previously providing benefits have been most likely to use ICHRAs. The proposed legislation aims to solidify the foundation of ICHRAs, ensuring their long-term viability and expanding their utility for both employers and employees.
The primary modifications involve statutory codification, renaming, and enhanced affordability features. The bill would codify the existing ICHRA regulations into federal law. Doing so provides a more permanent statutory foundation. It would also rename these arrangements to Custom Health Option and Individual Care Expense (CHOICE) arrangements. Critically, the legislation would permit employees enrolled in a CHOICE arrangement to use a salary reduction through a cafeteria plan to pay for the portion of their health plan premiums that they purchased through an Exchange. This provision would help workers save money on their premium payments by making the use of pre-tax dollars possible.
Furthermore, the budget bill seeks to incentivize small business adoption of ICHRAs/CHOICE arrangements. It would create a new two-year tax credit. Small businesses (fewer than 50 employees) offering a CHOICE arrangement for the first time would receive a tax credit of $100 per employee per month in the first year and $50 in the second. This measure is intended to encourage small employers, who often find traditional group plans unaffordable, to adopt this flexible, defined-contribution benefit. If passed, these changes would make ICHRAs/CHOICE arrangements a more attractive and financially accessible option for a wider range of employers and employees.
Ultimately, the ICHRA provisions discussed in this post were removed from the final version of the bill.
4. California SB 363: Mandated Denial Reporting and Fines for Health Plans
California Senate Bill 363, known as the Health Insurance Accountability Act, was introduced to address concerns about increasing healthcare denials by insurance companies. The bill is a legislative response to the rising rate of denied claims. Denied claims increased by an average of 20.2% between 2022 and 2023. California’s Department of Managed Healthcare (DMHC) also overturns 72% of health plan denials that reach it. The bill’s sponsor, Senator Scott Wiener, noted that there are currently no significant penalties to deter insurance companies from issuing wrongful denials.
The legislation requires health plans and insurers to annually report all treatment denials and modifications to the DMHC and the California Department of Insurance (CDI), effective in 2026. This reporting must be disaggregated by type of care (surgical, medical, and behavioral) and by age. Most significantly, SB 363 establishes administrative penalties for insurers with excessive rates of overturned denials. The plan becomes liable for fines if more than half of the Independent Medical Reviews (IMRs) in any of the three care categories result in an overturning or reversal of a denial.
The fines are substantial and escalate with subsequent violations. Fines start at a minimum of $50,000 for the first violation and at least $1,000,000 for each subsequent violation. The bill requires the DMHC and CDI to publish this denial information annually, promoting transparency. Funds generated from these penalties are intended to be reinvested by the state to provide healthcare services to Californians. Child healthcare services would be a primary focus for those funds. While the bill has support from various healthcare trade organizations, insurers are likely to oppose the mandatory disclosure and fines.
5. Tariffs and Health Plans: 10 Potential Impacts
The implementation of new tariffs on imported goods by the Trump administration is expected to have numerous indirect impacts on the healthcare sector and health plans, despite insurers being somewhat isolated from the immediate effects. The blog post outlines ten potential impacts. It identifies the most significant being an increase in overall healthcare costs and medical inflation. Tariffs on imported medical devices, supplies, and active pharmaceutical ingredients (APIs)—many imported from China and India—are projected to increase prices. Insurance companies, in turn, will likely pass those increased prices on to consumers through higher premiums, copays, and deductibles.
Beyond direct cost increases, tariffs introduce significant uncertainty into health plans’ actuarial analyses for pricing products. This uncertainty could lead to either over- or underestimated costs, with underestimation potentially contributing to losses. The tariffs also strain the supply chain. This could exacerbate existing drug shortages, particularly for generic medications. That in turn could force clinicians to prescribe more expensive alternatives, further increasing costs for plans.
Other potential impacts include broader economic effects, such as inflation or recession. Those effects could lead people from higher-margin commercial plans to be eligible for government-funded plans like Medicaid. For employer-sponsored plans, rising costs may prompt employers to shift the financial burden to employees or consider alternatives, such as ICHRAs. Ultimately, the cumulative effect of tariffs—including cost pressure on providers during contract negotiations and resulting higher premiums—means that health plans will need to focus heavily on ensuring premium rate adequacy over the next few years.
6. Cost Sharing Reductions (CSRs): Are They Back?
The possibility of Congress reinstating direct federal funding for Cost Sharing Reductions (CSRs) has prompted the Centers for Medicare and Medicaid Services (CMS) to issue guidance for 2026 rate filings. CMS directed issuers in certain states to submit two separate filings: one assuming CSRs remain unfunded (the current law) and one assuming Congress funds them. The ACA established CSRs. CSRs are federal subsidies intended to reimburse health insurance carriers for providing more generous cost-sharing benefits to eligible lower-income individuals enrolled in marketplace Silver plans. Congress halted direct federal payments for CSRs in October 2017.
Since 2017, “silver loading” has mostly covered the cost of CSR benefits, where insurers inflated the premiums specifically for their Silver plans. This action inadvertently increased the size of Premium Tax Credits (APTCs) because the ACA benchmarks those credits to the second-lowest Silver plan. As a result, the federal government is still indirectly subsidizing CSR costs through higher premium subsidies. That makes direct funding appealing to some lawmakers as a potential deficit-reducing measure, especially since enhanced APTCs will expire.
If Congress reinstates CSR funding, health plans will face significant operational and strategic changes. Carriers would need to prepare for CSR reconciliation—the process of calculating the cost difference between standard and CSR-enhanced plans for every claim. Many abandoned that function after 2017. Furthermore, the practice of silver loading would become irrelevant. Bringing back CSRs would require carriers to re-evaluate their pricing strategies. Doing so may result in lower Silver plan premiums and necessitate the submission of new rate filings based on the newly funded scenario.
7. Health Insurance Company Earnings: Q1 2025
First-quarter 2025 earnings reports from major U.S. public health insurance companies revealed key industry trends. Those trends primarily centered around elevated medical costs and utilization. It was particularly noticeable within the Medicare Advantage (MA) segment. UnitedHealth Group, the largest MA provider, specifically cited a sharp, unanticipated increase in care activities in its senior business as the reason for missing Wall Street estimates and lowering its full-year guidance. While Humana and Elevance Health also noted elevated costs, they framed them as either consistent with expectations or manageable. These statements reflect varied impacts and strategic adjustments across the industry.
Beyond MA, earnings calls highlighted the complexities within Medicaid. Primarily, insurers focused on the ongoing redetermination process and the adequacy of state-set rates to keep pace with rising costs. Centene, for instance, reported an increase in its Medicaid Health Benefits Ratio due to higher acuity among redetermined members and expenses associated with seasonal illnesses. Multiple companies noted seasonal illnesses contributed to utilization in the first quarter. Pharmacy costs also remained a significant focus, driven by high-cost specialty drugs. That led insurers to discuss incorporating these costs into state rate negotiations and tracking the adoption of biosimilars.
Despite these cost pressures, most companies reported strong revenue growth. Cigna, Elevance, CVS Health, Oscar Health, and Clover Health all met or exceeded expectations due to successful execution across their diversified segments. The mixed results led to varied revisions in full-year guidance. Cigna and Clover Health raised their outlooks, while UnitedHealth Group lowered theirs. Companies like Elevance and Humana reaffirmed their original targets, signaling an industry navigating complex cost trends with differing levels of operational preparedness.
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