Regulatory Roundup: ACA Subsidies, Washington Crackdown, Wyoming MedSup Changes

State-by-state variations of laws, compliance protocols, industry transparency, and general regulatory culture can lend one the impression that keeping up with industry changes is a little bit like herding cats. So, what better way to wrangle some of the more localized insurance news than in a Regulatory Roundup?

On an ongoing basis, in no particular order or rank, we’re wrestling the various regulatory changes, compliance actions, and commissioner decisions into our roundup. As a disclaimer: There’s a lot going on at any given time in these here United States, so this isn’t a comprehensive picture of state-level action by any means. Think of it, instead, as a sampler platter of regulation. 

Also important to note: If we’re recapping interpretations of legal decisions, this is some armchair insurance speculation and not at all legal advice. If you need legal advice, get a lawyer. 

States sound alarm on CMS rollback of ACA subsidies

Under the administration of President Donald Trump, the Centers for Medicare and Medicaid Services (CMS) final 2025 Marketplace Integrity and Affordability rule dials back the previously expanded Affordable Care Act subsidies. Many individuals and families that are enrolled in ACA plans on the federal website or through state exchanges qualify for subsidies that make their health care as affordable and sometimes more affordable than if they were able to get insurance through an employer (although, if you can get insurance through an employer, you don’t qualify for ACA exchange coverage or subsidies). New rules greatly reduce the benefits available to health care enrollees.

“These changes could have a significant impact not just on those who lose enhanced subsidies, but on everyone who depends on affordable coverage,” said Connecticut Insurance Commissioner Andrew Mais in a news release. “They could increase the number of uninsured individuals in our state, strain already overburdened hospitals and providers, and shift costs onto commercial insurance customers, including those using Access Health CT. That means higher premiums and real risk for many Connecticut residents.”

The state estimates that more than a third of current ACA enrollees in Connecticut could lose their health care coverage.

Vermont’s insurance department featured an article from Vermont Public in the monthly newsletter, noting that 45,000 Vermont residents could be at risk, as well. While 97 percent of Vermont residents have healthcare, 70 percent of them can afford it. But even that may be a high water mark thanks to the new federal legislation, said Mike Fisher at the Vermont Office of the Health Care Advocate. 

“Vermont’s health care system is really vulnerable, and a shock like this will destabilize the whole thing,” Fisher said. “We won’t be able to keep hospitals open. We’ll lose providers.”

The CMS change rolls back subsidies, saying that the expansion of who can qualify for subsidized health care coverage under the ACA incentivizes fraud and abuse.

“It’s clear to me that the Trump administration does not care about helping people find and keep affordable, meaningful health insurance,” said Washington state Insurance Commissioner Patty Kuderer in a news release. “It wants to restrict both who gets covered and the medically necessary services they can receive. The administration claims it’s needed to combat fraud and abuse, but that is simply not the case in Washington state. Our Exchange has robust safeguards in place to prevent improper enrollments. All this rule does is create widespread consumer confusion, impose complex administrative requirements for states and consumers, and increase premiums and out-of-pocket costs for thousands of people in our state.”

Washington cracking down on unlicensed and fraudulent businesses

Washington state has fined a health care sharing ministry for failing to register with the state and not meeting the state’s standards for minimum plans. The state has ordered the HCSM to cease and desist, and ordered that it pay taxes, penalties, and interest on its collected premiums.

Another state investigation continues to net penalties for everyone caught up in the fraud of Quick Health, also known as Seguro Medico. 

Washington Office of the Insurance Commissioner officials revoked the insurance licenses of an insurance agency and the agency’s sole licensed agent after the state found the agent continued to place business with Quick Health, despite the carrier having been exposed as a fraud. The producer and agency continued to represent false products to consumers, and can no longer do business in the state of Washington.

Wyoming updates birthday rule for Medicare Supplement guaranteed issue

Wyoming allows Medicare Supplement beneficiaries to switch plan providers annually as of June 4, 2025. The annual enrollment period for this Supplement change begins for each beneficiary on their birthday and lasts for 63 days afterward.

A new bulletin from the state updates insurers to let them know that, even if a person’s birthday was before June 4, 2025, an insurer must comply with the guaranteed issue period if that person applies to exchange coverage within the 63-day window after their birthday.

Beneficiaries can make the switch without a medical underwriting exam as long as they’re exchanging their current plan for an equivalent or less robust coverage plan. (E.g., if you have a Plan G, you can move to a Plan G or several of the other plans that provide lesser coverage, but if you have a Plan K, you can only really move to a Plan K.)

The Wyoming guidance document includes which plans can be exchanged for what. Historically, Medicare Supplement, also known as Medigap plans, have been quite steady for enrollees and the brokers who sell them. So, whether this guaranteed issue period encourages the kind of turnover that increases competition or simply destabilizes the market will be worth a watch.

Other state regulatory changes

Alaska has adopted regulations for pharmacy benefit managers (PBMs), including regulations for their registration and renewal, fees for registration and renewal, and required disclosures for the people who are working within the PBM. 

Arizona is changing to PSI Services for pre-licensing and continuing education services for the state, moving away from Prometric.

California brokers received a bulletin from the Surplus Line Association of California reminding them that a surplus line business entity needs to have at least one individually licensed surplus line broker named with the state.

Colorado has adopted an emergency regulation setting statewide subsidy levels for the health care plans under state regulation. Another bulletin guides health insurance carriers and PBMs about how to stay compliant with state reporting requirements to give consumers more transparency about the connection between coverage and pricing.

Connecticut Insurance Commissioner Andrew Mais announced his office had accepted a report from the Severe Weather Mitigation and Resiliency Advisory Council. The 48-page document outlines risks and possible mitigation measures that the state will work with county and local governments and agencies to implement when possible to reduce the risk for insurers and consumers alike.

Delaware General Assembly members voted to establish an auto insurance task force that will examine auto insurance rates and see what the state can do to lower skyrocketing insurance costs. The state also issued an alert to insurance carriers that they may have to get creative to help consumers obtain prescriptions within their coverage as a prominent pharmacy chain goes through bankruptcy and closes pharmacies throughout the state.

Florida Surplus Lines Service Office (FSLSO) is making changes to the SLIP filing system, adopting SLIP+, for surplus policies, including giving filers the ability to designate a policy as exempt.

Idaho will offer insurance licensing exams in Spanish Aug. 1, 2025, and has issued a bulletin for a property insurance market data call.

Louisiana has updated its continuing education requirements for producers and adjusters, effective Aug. 1, 2025. For those who will renew on or after July 31, 2027, continuing education will include at least two hours of education about legislative changes to state insurance law. The state also issued a notice of intent to amend regulation 120—if you want to skip the legalspeak, the essential thing to know is that, thanks to legislation in 2024, the Department of Insurance will be able to use digital means (i.e., email) to notify producers and others who fall in regulatory crosshairs.

Maryland has issued a report on the use of telematics in the state’s auto insurance market. A sample of the data: The percent of auto insurance carriers using telematics rose by 29 percent from 2022 to 2023, and 31 percent of auto policies in the market were enrolled in a telematics program in 2023. Data indicated more than half of the telematics-enrolled policies experience price fluctuations thanks to the telematic data.

Michigan is taking a repeat offender to task with a $50,000 fine after they issued 152 fraudulent insurance policies. Other Michiganders are in trouble with the state Department of Insurance and Financial Services, with: $15,000 in fines for using someone else’s information to get three insurance policies, $15,000 for faking auto documents to get insurance, losing an agency and individual license for hanging onto $700,000 in funds that were supposed to be remitted to an insurer on the insured’s behalf, losing an agency and individual license and owing a combined $10,000 for overcharging premiums for the purpose of pocketing the difference, and having a license revoked and owing $1,000 in fines for submitting fraudulent policies to get commissions.

Montana Commissioner of Securities and Insurance James Brown issued a memorandum to property and casualty insurers in the state to remind them that they shouldn’t nonrenew insurance policies based solely on wildfire risk unless there’s evidence that the risk has increased substantially.

North Dakota Insurance Commissioner Jon Godfread issued a news release reminding residents that timely claims submissions are key after a storm such as those that damaged roofs throughout the state at the end of June. The state has also merged its Insurance and Securities departments.

Ohio Insurance Director Judith French has taken action against a company that has been illegally selling policies to police officers and firefighters in the state. The company also stopped covering medical bills only two months into its plan year, leaving thousands of retired fire and police policyholders on the hook for surprise medical bills. One claimant was left holding a bill for more than $270,000. 

Oklahoma issued a bulletin to the industry to give guidance on how carriers and agencies should act to satisfy the provisions of Oklahoma SB 543, which was effective July 1, 2024. The act requires business entities with a board of directors to submit information security protocols to the insurance commissioner on an annual, proactive basis, and also outlines requirements for businesses to loop in the state when a data security event has occurred.

Utah increased its fingerprint fee from $27 to $32 for resident licensees in a variety of license classes, effective July 1, 2025. The Utah Insurance Department also repealed a rule that stopped someone from holding both a Title insurance and real estate license. You still can’t do that, but it became codified by the state legislature so the department finds their rule now redundant.

Washington Insurance Commissioner Patty Kuderer released a newsletter, Patty’s Takes, accompanying the latest episode of her office’s podcast, and it’s just straight fire. WILDfire. The NAIC also elected Kuderer to serve as Secretary/Treasurer for the Western Zone Committee. The Washington Office of the Insurance Commissioner has also extended an emergency rule that allows carriers to factor in a cost-sharing reduction into plans for plan year 2027.

Stay on top of regulatory changes with AgentSync

While these points of interest aren’t comprehensive, our knowledge of insurance producer and variable lines broker license and compliance maintenance is. See how AgentSync can help make you look smarter today; head over to the Compliance Library and wrastle up some state-by-state regulation and more jurisdictional updates. If you’re looking for a solution that builds regulations like these into your distribution channel management workflows automatically, AgentSync can help. See us in action or talk to one of our experts today.