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ACA Filing Assumptions Benchmark

The rate increases made headlines. This is what carriers actually assumed to get there: morbidity, trend and demographic factors parsed from every Unified Rate Review Template, weighted by projected enrollment.

CMS URRT public use files · PY2024 to PY2026 · As of March 27, 2026
+8.5%PY2026 enrollment-weighted morbidity adjustment, vs -0.1% in PY2025: a 8.6 pt regime shift
16% / 24%Share of enrollment filed with no morbidity change vs +15% or more. The market disagrees with itself
+6.3%PY2026 Rx cost trend, plus +4.0% utilization: the GLP-1 load, split
212 ptsWidest morbidity gap among the largest issuers: WellCare Health Insurance Company NJ +153.2% vs AmeriHealth HMO NJ at -58.9%

Carriers priced an essentially flat risk pool for two years. Then 2026.

Enrollment-weighted morbidity adjustment filed in individual market URRTs. Through PY2025, filed morbidity stayed within a point of neutral. PY2026 filings jumped 8.6 points in one cycle, pricing in the sicker pool left behind by enhanced subsidy expiry. The small group market is the control: its filed morbidity moved from +0.4% to +1.5%.

Filed morbidity adjustment, individual market

Enrollment-weighted percent change in URRT filings, PY2024 to PY2026

-5%0%+5%+10%-0.6%PY2024-0.1%PY2025+8.5%PY2026

There is no consensus morbidity assumption. There are two.

Distribution of PY2026 filed morbidity adjustments, by share of projected enrollment. The market split into camps: 15.6% of enrollment sits with filings that assumed no morbidity change at all, while 23.6% sits above +15%. The middle is thin. Part of the split is geography: Texas books priced the cliff while Florida's two largest filings, half the zero camp by weight, priced through it. But Florida, Georgia and Tennessee hold both camps inside the same state, and the PY2027 experience data will grade them.

Filed morbidity adjustment, PY2026 distribution

Share of projected individual market enrollment, by filed assumption

0%10%20%2.5%< -21.7%-2 to 015.6%0 (none)14.7%0 to 2.514%2.5 to 514.3%5 to 7.57.9%7.5 to 105.7%10 to 1523.6%15+Filed morbidity adjustment (% change), share of projected enrollment

Reading it: the darker bars mark the two camps. Weighted median +5.2%. The zeros are not bookkeeping: zero-camp filings also show below-market other-adjustment and demographic factors, and project roughly two years of plain trend in total claims (+21% vs +50% in the +15% camp), so a carrier filing at 0% against a market pricing +8.5% is genuinely claiming a better pool, or underpricing its renewal book.

Filed assumptions, 3 plan years

Enrollment-weighted averages across all individual market URRT filings. Trend rows are year-1 annualized factors. Click any assumption to see where it landed, state by state and carrier by carrier.

AssumptionPY2024PY2025PY2026YoY swing

Where the morbidity assumption landed hardest

Filed morbidity adjustment alongside the realized enrollment-weighted rate change, individual market. The two do not move in lockstep: a state can carry a moderate headline increase over an aggressive morbidity assumption, with the difference living in trend, demographics and plan design.

StateMorbidity adjRate changeEnrollment
ARArkansas
+29.9%+24.0%293,376
TXTexas
+19.8%+35.6%3,243,953
LALouisiana
+18.0%+24.3%253,017
MSMississippi
+16.9%+43.9%241,184
GAGeorgia
+16.2%+34.6%1,205,123
MOMissouri
+13.7%+23.0%310,359
OKOklahoma
+13.5%+27.1%281,806
KSKansas
+13.2%+26.3%160,697
MDMaryland
+12.5%+13.3%289,175
NVNevada
+12.1%+26.3%115,633

Issuers by projected membership

Every individual market issuer in the PY2026 file, largest first, all states. The zero-morbidity camp is not small carriers rounding: some of the largest books in the country filed no morbidity deterioration while peers in the same cycle filed +15% or more. Shaded cells mark zero-adjustment filings.

IssuerStateMorbidity adjRx cost trendRx util trendAvg members
Blue Cross and Blue Shield of TexasTX+16.9%+10.0%+2.2%789K
Health Options, Inc.FL+7.2%+5.0%+7.6%709K
Oscar Health Maintenance Organization of Florida, Inc.FL0.0%0.0%0.0%692K
Kaiser Foundation Health Plan, Inc.CA+3.0%+3.5%+5.7%664K
California Physicians' Service, dba Blue Shield of CaliforniaCA+0.7%+10.0%-0.1%633K
Centene Venture Company FloridaFL0.0%0.0%0.0%614K
UnitedHealthcare of Texas, Inc.TX+22.2%+2.9%+8.1%359K
Blue Cross Blue Shield of FloridaFL+6.3%+4.4%+9.9%333K
SelectHealth, Inc.UT+6.1%+11.8%+3.9%278K
Blue Cross Blue Shield of North CarolinaNC+8.5%+6.6%+5.7%265K
Horizon Healthcare Services, Inc.NJ+5.2%+8.8%+3.8%254K
Celtic Insurance CompanyTX+26.4%+7.7%+4.8%242K

Entries, exits and where the members went

Issuer licenses present in the PY2025 file but absent from PY2026, and vice versa, individual market. 34 filers left carrying 2.82M lives at their last filing; 28 entered carrying 73K. Book shifts among continuing issuers show where the members landed. Some exits are corporate consolidations rather than market withdrawals: the book moves to an affiliate under a different license, and the affiliate's growth appears in the shifts table.

Exited after PY2025StateLast book
Celtic Insurance CompanyFL963,528
Aetna Health Inc. (a FL corp.)FL565,522
Aetna Health Inc. (a PA corp.)NC312,222
Aetna Health Inc. (a TX corp.)TX237,375
Banner Health and Aetna Health Plan Inc.AZ105,915
Aetna Health Inc. (a GA corp.)GA94,328
Aetna Life Insurance CompanyNJ74,292
Aetna Health of Utah Inc.UT67,237
Entered for PY2026StateCurrent book
Ambetter HealthPA60,055
HealthPartners Insurance CompanyMN10,459
UPMC Health Plan, Inc.PA2,013
Access to Care Health PlanTX925
Ambetter Health of Texas, Inc.TXnew
UnitedHealthcare Insurance CompanySDnew
Bankers Reserve Life Insurance Company of WisconsinTNnew
Health Net Community Solutions of Arizona, Inc.AZnew
Largest book shifts, continuing issuersStatePY2025PY2026Change
Oscar Insurance Company of FloridaFL753,2101,124,915+49.3%
Blue Cross and Blue Shield of TexasTX1,316,0491,082,299-17.8%
Superior Health PlanTX256,070475,005+85.5%
Celtic Insurance CompanyTX296,984487,491+64.1%
Oscar Insurance CompanyTX119,961265,713+121.5%
Ambetter of Peach State Inc.GA506,771640,524+26.4%
Cigna HealthCare of Texas, Inc.TX138,89823,396-83.2%
Oscar Health Plan of GeorgiaGA343,195230,917-32.7%
Cigna HealthCare of GeorgiaGA137,35734,905-74.6%
Celtic Insurance CompanyIN105,6206,262-94.1%

Identity is the state plus HIOS issuer id; re-licensed entities with heavily overlapping names are treated as continuations, not churn. Enrollment is each issuer's current enrollment at filing (Worksheet 2). A zero-book entry is a new filer with no members yet at filing time.

The demand side: selections, net premiums and the mid-year curve

The assumptions above priced a pool-composition shock; this is the shock arriving. OEP 2026 closed at 23.13M plan selections nationally, -4.9% from 2025, while the average premium consumers actually pay after subsidy jumped by half or more in the states that filed the steepest morbidity. States are ranked by that net-premium jump. The mid-year column is each state's 2025 effectuated-enrollment trajectory (latest month vs January; positive means year-round special enrollment is still adding members, negative means the pool is already shrinking in-year).

StateOEP 2026 selectionsvs 2025Net premiumChange2025 mid-yearFiled morbidity
MSMississippi313,392-7.3%$41 → $131+219.5%-10.2%+16.9%
GAGeorgia1,324,295-12.3%$74 → $164+121.6%-1.6%+16.2%
OKOklahoma261,887-15.0%$78 → $161+106.4%-3.9%+13.5%
WVWest Virginia55,879-16.7%$101 → $208+105.9%-1.8%+2.0%
AZArizona357,144-15.6%$113 → $229+102.7%-0.9%+5.0%
LALouisiana296,648+1.2%$72 → $144+100.0%+10.1%+18.0%
NMNew Mexico83,103+18.1%$152 → $299+96.7%+8.8%+5.2%
TNTennessee569,310-11.4%$72 → $141+95.8%-8.0%+12.0%
ALAlabama455,776-4.6%$65 → $126+93.8%+0.1%+2.0%
NENebraska128,492-6.0%$114 → $217+90.4%+3.7%+0.6%

Sources: CMS Marketplace OEP state-level public use files (plan selections, average premium after APTC) and CMS effectuated enrollment tables (monthly state series). Net premium is the average consumers pay after advance premium tax credits; the 2025-to-2026 jump is the enhanced-subsidy expiry as experienced at the household level, the driver behind both the enrollment decline and the filed morbidity above.

Every assumption filed here gets graded

Each late October

The verdict file

CMS ships the initial PUF with final filed factors just as open enrollment opens, then trues it up each spring with quarterly refilings. This page rebuilds on both.

PY2027 onward

Assumptions vs actuals

The next cycle's experience data grades the +8.5% morbidity call, camp by camp. Did the zero-adjustment carriers know their pools, or miss the cliff?

Methodology

Source. CMS Rate Review Public Use Files (Unified Rate Review Template), plan years 2024 to 2026. Single risk pool, ACA-compliant plans; 2251 filings across both markets. Every filing carries its SERFF tracking number, company and HIOS issuer ID in the underlying data.

Weighting. Assumption factors are weighted by each filing's projected member months (Worksheet 1). Rate changes are plan-level cumulative changes weighted by current enrollment (Worksheet 2), renewing plans only: terminated plans keep their members in the file with a 0% "change" that is a crosswalk, not a rate action (2.33M PY2026 lives, 1.12M of them one Oscar Florida entity mid-consolidation), and new plans have no prior rate. Aggregates therefore reflect the rate action renewing members actually experience. Prior-year quarterly small group refilings shipped inside the annual PUF are excluded to prevent double counting.

Caveats. These are filed values, which can precede final state action in some jurisdictions. A zero morbidity entry can reflect a carrier embedding morbidity in other adjustment fields; the benchmark flags the filing as filed rather than reinterpreting it. Multiplicative URRT factors are restated as percent change.

Cadence. Rebuilt on each PUF release. Data as of March 27, 2026. Source: CMS Rate Review Data.