National Association of Insurance Commissioners urges Congress to extend ACA enhanced premium tax credits and clarify CMS authority for mid-year Marketplace rate adjustments

The National Association of Insurance Commissioners (NAIC) sent a letter to congressional leadership urging immediate action to extend the Affordable Care Act’s enhanced premium tax credits, which are scheduled to expire at the end of 2025. NAIC warned that the anticipated expiration is already disrupting state individual health insurance markets and will translate into sharp premium increases and enrollment declines. This was NAIC’s fifth letter to Congress since July 2024 on the issue. The regulators said that, absent an extension, average consumer out-of-pocket premiums would more than double versus 2025, with many facing even larger increases, alongside higher premiums, insurer exits, and steep expected declines in enrollment, particularly among young and healthy consumers. NAIC also urged Congress to clarify the Centers for Medicare & Medicaid Services’ authority to work with states on rate updates in the individual market, noting uncertainty over whether CMS can allow mid-year rate adjustments for Marketplace coverage, and arguing that clarifying this authority would help ensure the benefit of any credit extension is reflected in consumer rates as soon as possible. NAIC pressed for congressional action before Dec. 15, the deadline for most consumers to select coverage beginning Jan. 1, 2026, and offered to continue discussions with legislators on both the tax credits and broader drivers of healthcare costs and premiums.