2027 ACA rate filings price in a second morbidity load
Insurers are proposing a 15% median increase for 2027 on top of a finalized 20% for 2026, and the filings say plainly that the individual-market pool is now structurally sicker.
The 2027 ACA rate filings that became public after the July 15 federal deadline are not a repeat of last year's shock. They are the second installment of it. Insurers are no longer pricing a one-time disruption from expiring enhanced subsidies; they are pricing a permanently smaller, sicker individual-market pool, and they are saying so in the actuarial memos.
Derived from KFF preliminary and finalized rate-filing analyses, 2026. Index calculated from KFF median increases; not a KFF-published figure.
| Value (index (2025 = 100)) | Median premium index |
|---|---|
| 2025 | 100 index (2025 = 100) |
| 2026 | 120 index (2025 = 100) |
| 2027 | 138 index (2025 = 100) |
What the filings actually say about 2027 premiums
KFF's preliminary read of 77 insurers across 16 states and the District of Columbia found a median proposed 2027 premium increase of 14%, with 20 carriers asking for more than 20%. A broader review covering 276 insurers with public filings in all 50 states and DC put the national median at 15%. That follows a finalized 20% median for 2026, making this the second-highest requested cycle since 2018 and the second consecutive double-digit year.
Compounding matters more than any single number. If the proposed increases hold, typical premiums at participating Marketplace insurers would rise by more than one-third between 2025 and 2027. A member who paid $500 a month in 2025 is looking at roughly $690 in 2027 before subsidy effects, in a market where the subsidy cushion has already thinned.
A 15% median masks wide dispersion. The 20 insurers seeking more than 20% are telling regulators something different than the median suggests.
Morbidity is now a recurring line item, not a one-time adjustment
The most important detail sits in the rate build-up. Insurers attributed roughly 4 percentage points of their 2026 increases to a sicker risk pool, and they are asking for another 4 percentage points of morbidity load in 2027, according to the Peterson-KFF Health System Tracker. The second load is applied on an already adjusted base, which is what separates this cycle from a normal post-disruption correction.
The independent data supports the assumption rather than contradicting it. Wakely Consulting Group, using information covering roughly 80% of individual-market enrollment, estimated that 2026 morbidity deteriorated by 2.9% to 6.5% versus 2025. Fortune reported that 2.6 million Americans dropped ACA coverage as enhanced subsidies lapsed, and 2026 enrollment is estimated to have fallen 17% to 26% overall. Enrollees above 400% of the federal poverty level, $62,600 for a single person in 2026, lost premium assistance entirely. Those are disproportionately the healthier, price-sensitive members who make a pool work.
There is also a process wrinkle that leaders should not dismiss as technical noise. The 2027 Notice of Benefit and Payment Parameters was not finalized until after some carriers had prepared their filings, so several proposed rates rest on assumptions about rules that subsequently shifted. Expect revisions, and expect the revisions to skew upward rather than down.
The individual market is becoming a managed-runoff book
For payer executives, the strategic framing has changed. Product, network and care-management models built for a subsidized, comparatively young pool are now mispriced against members with materially higher acuity per enrollee. The practical responses are already visible in the filings: narrower networks, tighter utilization management, county-level withdrawals and a renewed dependence on risk-adjustment accuracy to avoid transfer-payment surprises.
The open question is whether a second compounding morbidity load makes parts of this market structurally unpriceable without reinsurance. Several carriers are hedging that view quietly, through service-area reductions rather than rate increases, which is the less visible but more durable signal. A 15% median masks wide dispersion; the 20 insurers seeking more than 20% are telling regulators something different than the median suggests.
Risk-adjustment performance becomes the swing factor. In a smaller pool with higher average acuity, documentation gaps and coding lag translate directly into transfer-payment losses that no pricing assumption can recover mid-year.
What provider CFOs and CIOs should model now
Provider-side finance leaders should model spillover rather than assume volume protection. Fewer covered lives at higher deductibles means more bad debt, more self-pay conversion and a longer cash cycle, even in markets where encounter volumes hold steady. Service lines with high elective content and high coinsurance exposure will feel it first, and the effect arrives in the revenue cycle before it shows up in admissions data.
For CIOs and analytics leaders, the pressure lands in three places: risk-capture workflows that feed submission accuracy, member-retention analytics that identify who is likely to drop coverage at renewal, and claims cost-trend tooling capable of separating true utilization change from pool composition change. Those are different problems, and systems that conflate them will produce confident forecasts that are wrong in the same direction two years running.
Health system contracting teams should also revisit exchange product assumptions in payer agreements. A narrower network in 2027 is worth a different rate than a broad one in 2025, and the leverage math shifts as carriers exit counties.
