MT| The Montana Commissioner of Securities and Insurance has issued an Advisory Memorandum with detailed guidance for health insurers regarding 2026 Affordable Care Act (ACA) plan filings, including deadlines, regulatory updates, and compliance expectations for both on- and off-exchange plans. Key updates include the adoption of new federal templates and actuarial tools, requirements for rate filings assuming the expiration of enhanced premium tax credits, and clarifications on network adequacy standards and essential community provider requirements. Insurers must closely monitor legislative changes, such as expanded hearing loss coverage, and ensure all filings—forms, rates, and network data—are submitted accurately and on time. The memo also emphasizes non-discriminatory benefit design, proper handling of prescription drug formularies, and the need for clear documentation and consumer-friendly rate justifications. Technical assistance and complaint handling will continue to be managed by the State Auditor’s Office, with all issuers expected to comply with both state and federal regulations.
Key Points:
- Filing Deadlines & Requirements: All plan, rate, and network adequacy filings for 2026 must meet strict deadlines, with updated federal templates and actuarial tools required for submission.
- Rate Setting & Premium Tax Credits: Insurers must file rates assuming the expiration of enhanced premium tax credits, with only one set of rates allowed, and be prepared to adjust if federal law changes.
- Network Adequacy & Provider Standards: Both federal and state network adequacy standards apply, with updated provider categories and continued focus on access, including for essential community providers.
- Benefit Design & Nondiscrimination: Plans must avoid discriminatory benefit designs, especially regarding age and chronic conditions, and comply with both state mandates and federal essential health benefit rules.
- Prescription Drug Coverage & Consumer Protections: Formularies must be clinically based and non-discriminatory, with clear exception and appeals processes, and all filings must include transparent, consumer-friendly justifications.