MD| The Maryland Insurance Administration Bulletin 26-6 sets 2027 ACA individual, small employer, and stand‑alone dental form and rate filing deadlines for Maryland carriers and outlines detailed content, format, and parity/accessibility requirements for those filings.
Key Issues:
- Carriers may use a phased (“piece‑meal”) strategy for 2027 ACA form filings due to the delayed federal NBPP, with early submission of core forms and blank benefit templates, followed later by updated schedule pages, AV calculator outputs, and supporting QTL documentation aligned to specified 2026 form and rate filing dates for individual, small employer, and stand‑alone dental products.
- General requirements include separate SERFF filings for forms and rates, no variability in cost‑sharing within a form (separate schedules per benefit design), identification of Exchange status and metal level, AV calculator screen prints, drug benefit certification to the EHB benchmark, and extensive MHPAEA financial requirement and NQTL comparative analyses consistent with federal parity guidance.
- For rate filings, carriers must submit the Unified Rate Review Template Parts I–III, demonstrate compliance with ACA rating rules and an 80% MLR, coordinate with MHBE QHP and Value Plan standards (including Exchange plan count limits and plan lists), ensure all PDFs meet WCAG 2.1 AA accessibility, file stand‑alone dental forms and rates together as Form/Rate in SERFF, and may not substitute essential health benefits in 2027 individual and small employer markets, consistent with Maryland’s long‑standing EHB substitution prohibition.