This week: Health insurance premiums for January 2026 renewals are coming in higher than many employers expected, especially in the fully insured small group market. In this week’s discussion, we break down why rates are increasing, including the impact of an aging risk pool, continued medical trend, and the long-term effects of healthier groups migrating to level-funded, captive, PEO, and ICHRA arrangements. We also highlight how carriers are responding—through changes to plan design, networks, and out-of-network protections—and what employers should understand as they evaluate their 2026 options. The charts below give a clear, data-driven view of what’s happening and why.
Employers and brokers across the country are seeing unusually steep increases on fully insured small group renewals — particularly for January 2026 groups that are currently in the middle of open enrollment.
Much of the national media has focused on the spike in ACA individual-market premiums. But the small group market is facing a very different set of pressures. The drivers behind 2026 rates involve structural issues in how the fully insured block is priced, who is still in that block, and how carriers are adjusting benefits to keep the market viable.
This article unpacks the forces behind these increases so brokers can explain the trend clearly, set expectations with employers, and frame renewal conversations around what’s changing — and why. We’ll also look at how carriers are responding with plan redesigns and network adjustments, and why shopping the market doesn’t always fix the underlying problem.
Fully insured small group pricing follows a rigid formula. Once you understand that formula, the 2026 increases make a lot more sense.
There are only three rating factors for small group plans:
Age.
Every member is rated at their 2026 age, and age bands get progressively steeper at older ages. With the fully insured block aging, this factor hits harder each year.
Geography.
Rates reflect the cost of doing business in each region — primarily provider contracts, hospital reimbursement, and local competition. The 2026 contract cycle came with particularly large increases from hospitals and major systems.
Medical trend.
This combines the cost of care (unit cost) and utilization patterns. For 2026, carriers are projecting higher trend due to rising hospital costs, new specialty drugs, inflation in outpatient services, and continued normalization of post-COVID utilization.
Equally important is what doesn’t affect pricing: claims history, underwriting, gender, or group health status. Because small group is community-rated, what happens to the overall block matters far more than what happens inside an individual employer group.

Equally important is what doesn’t affect pricing: claims history, underwriting, gender, or group health status. Because small group is community-rated, what happens to the overall block matters far more than what happens inside an individual employer group.
So why are renewals so much higher now than in recent years?
That’s what we’ll talk about next.
Three forces are making 2026 renewals feel more dramatic than in past cycles. The first is that health care is getting more expenses. This is known as medical “trend”.
Higher medical inflation.
Carriers are absorbing two years’ worth of major hospital contract renewals, a wave of new specialty drugs, inflation across outpatient and physician services, and a return to pre-pandemic care patterns. These factors combine into some of the highest trend projections we’ve seen since the ACA launched.
Example Components of 2026 Medical Trend
How different cost drivers add up
This table shows an illustrative breakdown of a hypothetical 9% overall medical trend for 2026. Actual assumptions vary by carrier and market, but the pattern is similar in many places: hospital costs and specialty drugs make up a large share of the increase.
| Trend Component | Illustrative 2026 Trend | What’s Driving It? |
|---|---|---|
| Inpatient Hospital | +10% – 12% | Higher contracted rates, labor costs, and complex cases that can’t easily be shifted out of the hospital setting. |
| Outpatient & Facility | +8% – 10% | Surgery centers, imaging, and outpatient procedures growing in volume and price. |
| Physician & Professional | +4% – 6% | Office visits, E&M codes, and specialist consults, plus higher staffing and overhead costs. |
| Traditional Pharmacy | +5% – 7% | Brand-name inflation, fewer deep generic discounts in some classes, and shifting formularies. |
| Specialty Drugs | +15% – 20% | New specialty and gene therapies, limited competition, and high per-member-per-month costs for a small number of people. |
| Other / Admin / Fees | +2% – 3% | Vendor fees, technology, care-management programs, federal and state assessments, and other overhead. |
These ranges are for illustration only and do not represent any specific carrier’s filed assumptions. You can adjust the numbers to align with the trend guidance you’re seeing in your own block or from particular insurers.
People get older every single year. And when they do, their prices go up, because small group plans have one-year age bands. We all know that. But not everyone knows this:
Not all age-rated renewal increases are created equal.
In both the individual and small group markets, carriers use the federal standard age curve from HHS to determine how premiums increase as people get older. And it really is a curve (sort of), not a straight line. But, as you can see below, it’s actually quite choppy, with some ages moving only a fraction of a percent and others jumping several percentage points. For example, going from age 37 to 38 increases the factor by only about 0.6%, while moving from 51 to 52 increases it by roughly 4.7%. Because of this uneven pattern, groups with several older employees (or small groups with just one or two) can see a meaningful portion of their renewal driven solely by the built-in age curve, even before medical trend or block performance is applied.
Federal Default Age Curve and Annual Increase
Impact of getting one year older (ages 21–64)
This table uses the federal default age curve for small group and individual coverage, with age 21 = 1.000. The % increase vs. prior age shows the change from the immediately preceding age (for example, age 50 vs. age 49).
| Age | Rate Factor | % Increase vs. Prior Age |
|---|---|---|
| 21 | 1.000 | 3.1% |
| 22 | 1.000 | 0.0% |
| 23 | 1.000 | 0.0% |
| 24 | 1.000 | 0.0% |
| 25 | 1.004 | 0.4% |
| 26 | 1.024 | 2.0% |
| 27 | 1.048 | 2.3% |
| 28 | 1.087 | 3.7% |
| 29 | 1.119 | 2.9% |
| 30 | 1.135 | 1.4% |
| 31 | 1.159 | 2.1% |
| 32 | 1.183 | 2.1% |
| 33 | 1.198 | 1.3% |
| 34 | 1.214 | 1.3% |
| 35 | 1.222 | 0.7% |
| 36 | 1.230 | 0.7% |
| 37 | 1.238 | 0.7% |
| 38 | 1.246 | 0.6% |
| 39 | 1.262 | 1.3% |
| 40 | 1.278 | 1.3% |
| 41 | 1.302 | 1.9% |
| 42 | 1.325 | 1.8% |
| 43 | 1.357 | 2.4% |
| 44 | 1.397 | 2.9% |
| 45 | 1.444 | 3.4% |
| 46 | 1.500 | 3.9% |
| 47 | 1.563 | 4.2% |
| 48 | 1.635 | 4.6% |
| 49 | 1.706 | 4.3% |
| 50 | 1.786 | 4.7% |
| 51 | 1.865 | 4.4% |
| 52 | 1.952 | 4.7% |
| 53 | 2.040 | 4.5% |
| 54 | 2.135 | 4.7% |
| 55 | 2.230 | 4.4% |
| 56 | 2.333 | 4.6% |
| 57 | 2.437 | 4.5% |
| 58 | 2.548 | 4.6% |
| 59 | 2.603 | 2.2% |
| 60 | 2.714 | 4.3% |
| 61 | 2.810 | 3.5% |
| 62 | 2.873 | 2.2% |
| 63 | 2.952 | 2.7% |
| 64 | 3.000 | 1.6% |
For a group, you can read this as: if the average age of the group increases by one year, the portion of the renewal driven by age alone will generally fall in the range shown above, before you layer on medical trend or changes in the carrier’s overall block.

A major — and often overlooked — driver of 2026 premiums is the continued contraction of the fully insured small group market. Every year, a disproportionate share of the healthiest groups migrate out of fully insured plans and into level-funded arrangements, captives, PEOs, and ICHRAs feeding the individual market. These groups leave because they can better capitalize on their favorable risk profile elsewhere.
As a result, the employers who remain in the fully insured block skew older, higher cost, and less predictable. Even groups with stable claims can feel the impact because premiums must be high enough to keep the overall block solvent and maintain MLR compliance.
The result: carriers are pricing into a pool that is getting smaller, older, and more expensive at the same time. Combined with medical trend and age-curve effects, this shrinking risk pool is a major reason 2026 increases feel sharper than in prior years.
Fully Insured Small Group Enrollment
2013–2026
Sources: CMS Medical Loss Ratio (MLR) Public Use Files, Small Group Market Enrollment (2013–2023). Values for 2024–2026 are illustrative projections based on observed market contraction trends.
| Year | Enrollment (Millions) |
|---|---|
| 2013 | 16.8 |
| 2014 | 15.2 |
| 2015 | 14.3 |
| 2016 | 13.7 |
| 2017 | 12.9 |
| 2018 | 12.5 |
| 2019 | 11.9 |
| 2020 | 11.4 |
| 2021 | 11.0 |
| 2022 | 10.6 |
| 2023 | 10.3 |
| 2024 (Est.) | 10.1 |
| 2025 (Est.) | 9.9 |
| 2026 (Est.) | 9.7 |

Carriers aren’t just increasing premiums; they’re redesigning products to maintain viability in a tougher risk environment.
Plan design adjustments.
Many 2026 plans include higher deductibles and OOP maximums, fewer office-visit copays, more coinsurance-based structures, higher specialty drug tiers, and more “deductible-first” benefits. Carriers are pushing plan designs toward the upper limits of each metal tier’s actuarial value.
Network tightening.
Expect more narrow-network PPOs and EPOs, more HMO-like structures, and in some cases the removal of out-of-network benefits altogether. Other carriers retain OON coverage but eliminate the OON OOP maximum, effectively making out-of-network care unlimited liability. Narrower networks help carriers negotiate better rates and slow trend growth.
Actuarial constraints.
Metal tiers create hard boundaries. Carriers can’t degrade benefits indefinitely, but they can adjust within those ranges — and many 2026 plans are sitting right at the edge of allowed AV limits.
These changes show that carriers are trying to balance affordability, actuarial requirements, and market competitiveness in a challenging environment.
Common 2026 Small Group Benefit Changes
How carriers are adjusting plan designs
Many fully insured small group plans for 2026 include a combination of higher cost sharing and tighter coverage. This table summarizes common changes brokers are seeing in the field.
| Benefit Area | Typical 2026 Change | What It Means for Members |
|---|---|---|
| Deductibles | Higher individual and family deductibles, especially on lower-premium plans. | Members must pay more out of pocket before the plan starts sharing costs. |
| Out-of-Pocket Maximums | OOP limits moved closer to the federal maximum; fewer “rich” plan designs. | Higher worst-case exposure if someone has a serious illness or accident. |
| Office Visit Copays | Higher copays, or visits moved to deductible/coinsurance first on some plans. | Routine visits may cost more out of pocket, especially for specialists. |
| Emergency Room | Increased ER copays, often combined with coinsurance after the copay. | Higher upfront cost for ER visits; more incentive to use urgent care where appropriate. |
| Rx Copays & Tiers | Higher copays, more tiers, and more drugs subject to coinsurance or higher specialty tiers. | Members may see larger jumps at the pharmacy counter, especially for brand and specialty drugs. |
| Networks | More narrow networks, more HMOs/EPOs, and in some cases no out-of-network coverage. | Fewer in-network provider choices and higher risk if going out of network without realizing it. |
| Out-of-Network Protection | Some carriers removing the OON out-of-pocket maximum on certain plans. | Members using non-network providers could face unlimited financial exposure. |
| Telehealth & Virtual Care | More emphasis on virtual visits, sometimes at lower cost than in-person care. | Lower-cost access point — but members must understand when and how to use it. |
Not every carrier will make all of these changes for 2026, but many small employers will see some combination of higher cost sharing, narrower networks, and tighter out-of-network protections as carriers try to manage rising claims costs.
The most important message for employers is this: the increase isn’t usually about them.
Fully insured groups are rated based on the overall block, not their own claims. A clean year doesn’t guarantee a favorable renewal if the risk pool is deteriorating.
This also explains why two nearly identical groups can see very different outcomes. Small differences in age mix, location, or the timing of healthier groups exiting the market can produce meaningful differences in renewal results.
In effect, the fully insured small group market is becoming a shrinking risk pool (the portion of the market where employers who cannot qualify for or access alternative funding arrangements must remain — still guaranteed issue, but often more expensive). Groups that have the demographics or stability to leave often do so. Groups that can’t leave remain. This creates a persistent cycle of adverse selection that raises costs for everyone who stays.
For many employers, fully insured coverage is increasingly a default option, not a strategic one.
This is the uncomfortable part: nobody — not carriers, not policymakers, not economists — has a complete solution to the fully insured market’s deteriorating risk pool.
Washington has no consensus plan, and most policy proposals fail to confront the math: when healthier groups leave, premiums must rise for those who remain.
Some policymakers have suggested shifting certain high-cost conditions into federal programs, similar to how ESRD and ALS are already carved out today. While this could relieve pressure on employer risk pools, expanding the model raises thorny questions: reimbursement levels, provider participation, unintended incentives, and long-term political feasibility.
Others argue for expanding public coverage more broadly, but federal programs have struggled with operational reliability — a concern highlighted during recent government shutdowns.
The truth is, the industry may not need a compromise between the current ideas so much as it needs entirely new ones: alternative approaches to risk pooling, redesigned catastrophic protection, and non-traditional financing models that rethink how high-cost claims are shared.
For now, employers and brokers are left navigating a system where the underlying math keeps getting harder — and where the search for durable solutions is still very much underway.
The forces driving 2026 small group premiums are structural and long-running: rising medical trend, an aging population, ongoing migration of healthier groups into alternative funding, tighter networks, and the mathematical limits of ACA community rating.
Brokers can help employers by shifting the conversation from just “what is my renewal?” to “why is this happening?” Why trend is accelerating, why the risk pool is deteriorating, why carriers are modifying plan designs, and which funding alternatives may be appropriate for the group.
The fully insured market isn’t collapsing — but it is changing, and faster than many employers realize. Understanding these dynamics positions employers to make better decisions and prepares them for the volatility ahead.
Feel free to share this article with clients as a resource, and stay tuned for our upcoming video walkthrough of the 2026 renewal landscape.
