Consistent with 28 TAC Section 3.505, health benefit plan issuers subject to that section must submit rate filings for 2026 to TDI no later than June 15, 2025. However, since June 15 falls on a Sunday this year, TDI will accept rates submitted by Monday, June 16, 2025.
Issuers can find rate filing templates on TDI’s website at the following link: www.tdi.texas.gov/health/ratereview.html. These templates include the actuarial value (AV) and cost-sharing factor spreadsheet that reflects a cost-sharing reduction (CSR) adjustment factor of 1.40 for 2026. This is consistent with TDI’s rule amendments adopted earlier this year.
Rate filings submitted to TDI by the June 16 deadline should reflect assumptions that are consistent with available data and state and federal law as of the day the rates are filed. If adjustments are needed based on risk adjustment reports or other issues, TDI will accept updated rates on or before July 16, 2025. If there are material changes in federal funding, TDI will accept updated rates on or before July 30, 2025. Issuers should contact TDI at the email below if additional guidance is needed.
Early submission of rates and adjustments will greatly assist TDI in being able to complete its review before the federal deadline of August 13, 2025, in order for plans to be permitted on HealthCare.gov.
TDI also encourages issuers to review recent CMS bulletins and FAQ:
- Plan Year 2026 Individual Market Rate Filing Instructions (May 2, 2025) – requires issuers to provide specific CSR data and address CSR issues in actuarial memoranda.
- Frequently Asked Questions on Plan Year 2026 Individual Market Rate Filing Instructions (May 27, 2025) – provides examples of a reasonable methodology that issuers can use to estimate the amount of actual CSRs paid for enrollees in plan year 2024.
- Offering of Off-Exchange-Only Plans Without “CSR Loading” (May 2, 2025) – issuers are encouraged to offer plans without a CSR load that are sold exclusively off-exchange.
For more information, contact RateReview@tdi.texas.gov.