MI| Michigan DIFS Bulletin 2026-14-INS sets comprehensive Plan Year 2027 (PY27) filing, contract, rating, and wellness requirements for individual and small group medical plans offered on- and off-Marketplace, including strict timelines, template and documentation standards, actuarial and benefit design rules, and continued expectations around network adequacy, mental health parity, and consumer protections.
Key Points:
- On‑Marketplace plans have additional obligations, including use and filing of the 2021 SBC form (plan‑specific, URL‑linked, and tied to Plan IDs), accreditation by an approved body (NCQA, URAC, or AAAHC), and tight CMS/DIFS‑managed data correction windows, and all plans offering wellness programs must ensure they meet federal rules, are part of the approved filing, are not contingent on COVID‑19 vaccination status, and in small group tobacco‑rating scenarios include a health‑contingent tobacco cessation component that can reduce or eliminate the tobacco surcharge.
- Issuers must submit complete SERFF Form/Rate filings and Binders (with all validated federal and Michigan templates, including URRT, Rates Table, Network Adequacy, Plan ID Crosswalk, and checklists) by May 13, 2026 for small group and May 27, 2026 for individual, with issuer‑initiated rate changes allowed only at the Market Adjusted Index Rate level through July 13, 2026 and subject to detailed actuarial justification.
- Plans must comply with extensive contract standards, including readability thresholds (Flesch score ≥45, minimum 10‑point font, table of contents), formal grievance and external review procedures, AV and de minimis rules using the Final 2027 AV Calculator, Michigan’s 2022 EHB benchmark, MHPAEA (including NQTL comparative analysis filing), autism and therapy visit minimums, and prohibitions on actuarially equivalent EHB substitutions.
- Rating requirements limit variation to rating area, age (3:1 using the federal default age curve), and tobacco (up to 1.5:1, potentially age‑varying), require separate individual and small group risk pools and per‑member rating in small group, and direct issuers to assume expiration of ARPA/IRA enhanced APTCs and absence of CSR payments for PY27 while separately disclosing the impacts and CSR load methodology in the actuarial memorandum.
- Network and service area rules emphasize no non‑network plans, robust network adequacy documentation (Michigan Network Adequacy Template FIS 2385 and related attestations), controlled service area changes via DCR with DIFS and CMS approval, adherence to ECP and patient safety standards, and transitional policy extensions only through December 31, 2027, with clear requirements for plan withdrawal and guaranteed renewability.