26-11 - Health Insurance Revised Rate and Form Filings for Plan Year 2027, August 7, 2026

The Missouri Department of Commerce and Insurance issued Insurance Bulletin 26-11 on August 7, 2026, directing all health carriers writing health insurance or health benefit plan coverage in Missouri to revise their Plan Year 2027 rate and form filings. The directive follows a July 16, 2026 order from the U.S. District Court for the District of Maryland in City of Columbus v. Kennedy, No. 26-2215, which stayed certain provisions of the Notice of Benefit and Payment Parameters for 2027 (91 FR 29256), including provisions related to standardized and non-standardized plans. CMS notified the Department on August 4, 2026, of its expectations for Plan Year 2027 rate and form filings in light of the court order. CMS issued two documents: a bulletin outlining a revised QHP data submission and certification timeline for Plan Year 2027, and a guidance letter titled 'Guidance on Standardized Plan Options and Non-Standardized Plan Option Limits and Exceptions in Light of Stay Order in City of Columbus v. Kennedy, No. 26-2215 (D. Md.).' Because Missouri is a state where CMS enforces ACA market-wide reforms, carriers must update form filing submissions to comply with standardized plan option requirements by August 12, 2026, filing revisions with both the Department and CMS. Missouri is an Effective Rate Review state and is therefore the primary regulator for rates. To meet the revised federal timeline for final rate determinations on August 28, 2026, the Department requires carriers to file rate revisions by noon Central Time on August 17, 2026. The expedited review process limits permissible changes to those required to comply with the court order and immediate downstream actuarial impacts resulting from those changes. Required rate filing materials include revised documents from the URRT tab in SERFF, a redlined actuarial memorandum, a concise overview of actuarial memorandum changes, a Rate Table Template in Excel format, Actuarial Value Calculator screenshots, an updated AV and Cost Sharing Design by Plan template, and an attestation that only court-order-compelled revisions have been made. Form filing procedures differ depending on whether a filing is closed or currently open, with closed filings requiring a reopening request via email to productfilings@insurance.mo.gov citing the SERFF tracking number.