ALL 50 STATES AND DC · CMS RATE REVIEW · PULLED SEPTEMBER 17, 2026
What do insurers want to charge you in 2027?
15.3% more for marketplace plans. 14.5% more for employer group plans. Flat isn't on the menu anywhere.
They've already filed it with state regulators. It's public, it's state by state, and it's here before your broker brings you a renewal. Requested, not approved: regulators can trim these before October.
Every state
What did insurers file where your people live?
Six columns, one row per state. The last three are the ones your renewal packet won't have: whether marketplace plans actually cost less than group plans in your state, whether a PPO is even filed in your counties, and what a mid-level plan runs in a typical county.
| State | Marketplace 2027 requested | Group 2027 requested | Marketplace costs less per member | Counties with a PPO | Lowest cost silver, age 40, typical county |
|---|
What changed that you probably haven't been told
Five things moved between mid-2025 and today
| When | What | What it means for you |
|---|---|---|
| September 2026 | ICHRA is now called a CHOICE Arrangement | CMS and the Small Business Administration adopted the new name on September 14, 2026. The regulation didn't change and there's no new tax credit. If a write-up says "ICHRA is now CHOICE, with a tax credit," the first half is true and the second half isn't yet. |
| December 31, 2025 | Enhanced marketplace subsidies expired | A 3-year extension passed the House on January 8, 2026 and hadn't been enacted as of August 2026. If you run a CHOICE Arrangement or QSEHRA, the allowance that cleared the affordability test in 2025 needs a fresh look. |
| January 1, 2026 | Bronze and catastrophic plans count as high-deductible plans | An employee on a bronze marketplace plan can now fund an HSA. Before 2026, most couldn't. Allowance plus bronze plan plus HSA is a real structure now. |
| January 1, 2026 | Direct primary care no longer breaks the HSA | A membership up to $150 per month individual or $300 family is no longer disqualifying coverage, and the fee is a qualified medical expense. The telehealth-before-deductible safe harbor also became permanent. |
| January 29, 2026 | The 2027 out-of-pocket maximum rose 13% | $12,000 self-only and $24,000 family, up from $10,600 and $21,200. That's the ceiling an employee can be exposed to inside a compliant plan. Some write-ups still print $10,150 for 2026; the June 2025 final rule superseded it. |
What to do with it
Your renewal is a number. What are you allowed to change about it?
The rate filing sets the market. It doesn't set your cost. Two companies in the same state with the same headcount can land 20% apart, and the difference is what's inside the plan, not which insurer is on the card.
Three questions worth asking before you sign:
| 1 | Does every rebate on my employees' prescriptions come back to my plan? On a standard insured plan you can't ask. On a self-funded one you can. |
| 2 | If we moved to marketplace plans, can my people keep their doctors? In 18 states no county has a PPO or POS plan at all. |
| 3 | What would it cost to add a $0-copay layer instead of raising everyone's deductible? Under $100 per employee per year for pharmacy. It lowers claims and improves the benefit at the same time. |
Design changes have landed at $2,000+ per employee per year in real client projects, with about $988 per employee per year in new cashflow on top of that and independent of it. About $100K per year for every 50 people. $0 upfront, billed out of savings. Same broker, same doctors, same cards.
See the 12 designs compared · Check PPO availability in your county · Benchmark your current cost
Results vary by group size, plan design, and utilization.
Where these numbers come from
Rate changes are the midpoint of what each insurer requested in that state, from the CMS rate review service, pulled September 17, 2026. All 2027 figures are proposed and still under review. Regulators can trim them, and approvals land in October.
"Marketplace costs less per member" compares the 2026 average premium per member per month from the insurers' own filings, marketplace against small group, weighted by enrollment. It is a price comparison from one source on both sides. It is an average across each plan's enrolled mix, not a same-metal, same-plan-type quote. A true like-for-like comparison at the same age and metal level is possible in only 2 states from public files, because small group rate tables sit in state filing attachments rather than any published dataset.
PPO availability counts every plan filed in every county for 2026 and asks whether any of them is a PPO or POS. Lowest cost silver is the median across that state's counties for a 40-year-old non-smoker, before any subsidy.
Nothing here is a quote.
