Green Mountain Care Board Receives 2026 QHP Rate Requests Amid Rising Health Care Costs
Montpelier, VT – On May 12, 2025, the Green Mountain Care Board (GMCB) received the 2026 individual and small group health insurance premium rate filings from BlueCross and BlueShield of Vermont and MVP Health Plan. The filings will be posted on GMCB’s rate review website. The average rate increases being requested are shown below:
Last week I wrote about the latest state of play regarding House Republicans so-called "big beautiful bill" to gut Medicaid in order to give fat tax cuts to billionaires. Yesterday the first official version of the legislative text was released, and it's pretty much as ugly as you might expect.
...The plan caters more to the moderate wing of the Republican party by omitting two of the biggest and most politically controversial proposals discussed: a per-capita cap on people who get coverage from Medicaid expansion, and a direct lowering of the federal matching rate.
Finally, there's over 1.6 million exchange enrollees who earn more than 400% FPL.
While enrollees in every other income bracket will be hit hard by IRA subsidies expiring, and many of them would be seriously damaged by Silver Loading being phased out, in terms of hard dollars, it's the middle-class enrollees being kicked back off the "Subsidy Cliff" again who will see the most jaw-dropping premium hikes.
Not only would they lose eligibility to any federal financial assistance, they'd also be hit with 6 full years of medical inflation (remember, the original ARPA/IRA subsidies have been in place (retroactively in some cases) since January 2021).
It's not gonna be pretty.
Finally, there's over 900,000 enrollees whose household income is simply unknown.
Next, let's look at the 200-400% FPL brackets. These make up almost exactly 1/4th (24.7%) of total ACA exchange enrollment this year.
These ~6 million enrollees are the ones who will be hit with a double whammy if both the IRA subsidies and Silver Loading end next year: Not only will they be hit with skyrocketing monthly premiums due to dramatically less-generous APTC subsidies, but they'll be far less likely to be able to use what subsidies they do receive to enroll in lower-deductible Gold plans (which cover ~80% of average claims) vs. Silver plans (which only cover 70-73% of average claims, depending on whether they include CSR help or not).
Turning to the 100 - 200% FPL range (and ignoring Medicaid expansion), 63% of all exchange enrollees fall into this income range (up from 61% last year).
That's over 15.2 million people total, and with extremely rare exceptions, just about every one of them should be enrolled in a Silver CSR plan, aka "Secret Platinum", since the extremely generous Cost Sharing Reduction (CSR) assistance in the 100 - 200% FPL range turns Silver plans (which normally have a ~70% Actuarial Value) into either an 87% or 94% AV plan...effectively Platinum (90% AV)).
In layman's terms, High CSR Silver plans have either free or extremely low premiums along with extremely low deductibles & co-pays.
This is, of course, extremely important since household income is one of the most critical factors in calculating how much financial assistance enrollees receive (or if they're eligible for Advance Premium Tax Credits (ATPC) at all).
Since there's so many income bracket columns and there's a lot to delve into for many of them, I've broken the full spreadsheet out into three sections/posts. The first focuses on exchange enrollees who earn less than 138% of the Federal Poverty Level (FPL). This is a critical threshold because it's the cut-off point for ACA Medicaid expansion enrollment in the 40 states (+DC) which have expanded it.
Nationally, over 31% of all exchange enrollees earn less than 138% FPL, which may sound surprising given that 41 states have expanded Medicaid...until you realize which states haven't done so yet: Over 4.5 MILLION enrollees in Florida and Texas alone earn less than 138% FPL (2.4 million & 2.1 million respectively).
If you've ever wondered why healthcare wonks (myself included) almost never even bring up the ACA's Catastrophic Level plans and why the only time I ever discuss Platinum Plans is in the context of high-CSR enrollees being eligible for "Secret Platinum" plans (labeled as Silver), this table should explain why.
Catastrophic ACA plans aren't available at all 10 states, and only 0.24% of enrollees choose Catastrophic plans in the other 40 states (+DC)...just 54,000 nationally (which is also down several thousand y/y). Of the states that even offer them, Catastrophic plans don't reach higher than 2.4% of the ACA exchange market, and that's only in DC and Minnesota...just 4,000 people in both.
At the opposite end, Platinum plans are only available in 19 states (+DC)...and again, just 0.5% of all exchange enrollees choose Platinum plans (even in those 20 states it's only 1.0%). This ranges from virtually none in TN, WV & IN to 15.7% in Hawaii.
Next up: Age brackets, gender, racial/ethnic groups and urban/rural communities. I'm also throwing in the stand-alone Dental Plan table here for the heck of it since I don't know where else to include it.
I don't have a ton to say about any of these, really. 10.6% of ACA exchange enrollees are children; 38.2% are under 35. It's also always interesting to me to see that 1.7% of ACA exchange enrollees are 65 or older.
Alabama has the lowest percent of enrollees under 18 (3.6%), while Utah has the highest (27.8%) which I guess makes sense since Utah has the youngest median-aged population in the country. Similarly, Utah has the highest percent of enrollees under 35 (58.6%) vs. Hawaii's 26.2% (lowest).
Next up: Premiums, Advance Premium Tax Credits (APTC) and Cost Sharing Reduction (CSR) assistance.
Nationally, the average unsubsidized premiums for 2025 exchange-based Open Enrollment Period enrollees is $619/month, up $14 or just 2.3% from $605 last year.
This is a noteworthy because 2025 ACA exchange premiums "should" have increase by more like 6-7% on average. This discrepancy is mostly because that 6-7% assumed that 100% of those enrolled in each plan in 2024 renewed the exact same policy (without any attrition or additional enrollment), which of course is never the case...even if total QHP selections were identical year over year, not all of the enrollees would be the same people, millions of them would switch to different policies and so on.
New Hampshire has the lowest average ACA premiums for the second year in a row at $469/month, while West Virginia once again has by far the highest at a whopping $1,170/month...up $51 from last year. Again, these are the unsubsidized average prices.
Now it's time to move on to the actual demographic breakout of 2025 Open Enrollment Period (OEP) Qualified Health Plan (QHP) enrollment.
First up: Breaking out new enrollees vs. existing enrollees who either actively re-enroll in an exchange plan for another year or who passively allow themselves to be automatically renewed into their current plan (or to be "mapped" to a similar plan if the current one is no longer available).
Nationally, 17% of all exchange QHP enrollees were new this year. The other 83% are current enrollees who signed up for another year, either actively (39%) or passively (45%).
New York had the lowest percent of new enrollees (11%), while Minnesota had the highest at 28%.
As I've noted before, there's still a massive divide between federal and state-based exchanges when it comes to active renewals: Over 45% of federal exchange states actively renewed (which is good!)...but only 22% of state-based exchange enrollees did. Active renewals range from just 8% in Rhode Island & DC to 58% in Utah.
