Enhanced Subsidies Expired — 400% FPL Hard Cliff Now in Effect for 2026
The enhanced premium tax credits that extended ACA subsidy eligibility above 400% of the Federal Poverty Level (~$62,600 for an individual) expired at the end of 2025 and were not renewed by Congress. Effective January 1, 2026, the hard subsidy cliff is back: income at or above 400% FPL produces zero premium tax credit. Arizonans who were receiving subsidies above this threshold and did not adjust their plans during open enrollment may be seeing significantly higher 2026 premiums. Anyone who enrolled expecting a subsidy above 400% FPL should verify their current subsidy status immediately.
Medicare Part D Out-of-Pocket Cap Now Fully in Effect — $2,000 Annual Maximum
The Inflation Reduction Act's $2,000 annual out-of-pocket cap on Medicare Part D prescription drug costs is now fully in effect for 2026. Beneficiaries who hit this cap pay nothing further for covered Part D drugs for the remainder of the calendar year. This is a significant change for Arizona Medicare members who take expensive specialty medications. The change also eliminates the previous "donut hole" coverage gap that affected many beneficiaries. Medicare Advantage enrollees should confirm their plan's specific drug cost structure, as plan designs have adjusted in response to this change.
DIFI Issues Guidance on Healthcare Sharing Ministry Disclosure Requirements
The Arizona Department of Insurance and Financial Institutions issued updated guidance clarifying disclosure requirements for organizations marketing healthcare sharing plans to Arizona consumers. The guidance reaffirms that sharing plan organizations must prominently disclose — at the point of first contact with a prospective member — that sharing plans are not insurance, that payment is not guaranteed, and that the organization is not regulated by DIFI. Brokers who recommend sharing plans are reminded that Arizona requires separate E&O coverage for sharing plan placements. DIFI indicated it will increase market conduct reviews of sharing plan marketing materials in 2026.
Two Carriers Exit Maricopa County ACA Market for 2026 — Network Changes Widespread
Two insurance carriers reduced their 2026 ACA marketplace footprint in Maricopa County, leaving some zip codes with fewer plan options than prior years. Consumers in affected areas who were auto-renewed into plans that are no longer available in their zip code have been transitioned to alternative plans by healthcare.gov — but the replacement plan may have a different network, different premium, and different deductible than expected. Arizona consumers should log into healthcare.gov to confirm their current 2026 plan, verify their network includes their providers, and check their current monthly premium against what they anticipated.
No-Surprises Act Enforcement Strengthened — Independent Dispute Resolution Updates
CMS announced updates to the No-Surprises Act independent dispute resolution (IDR) process, following federal court rulings that had temporarily disrupted the arbitration mechanism for out-of-network billing disputes. The updated process restores a more balanced methodology for arbitrators to determine appropriate payment rates between providers and insurers. For consumers, the practical impact is that the NSA's core protection — limiting surprise out-of-network bills to in-network cost-sharing amounts for emergency care and certain non-emergency services — remains intact and enforceable.
Issue-Age Accident and Hospital Indemnity Pricing Stable — New Entrants Increasing Competition
The Arizona supplemental insurance market saw several new carrier entrants in Q4 2025, increasing competition in the accident medical expense and hospital indemnity categories. Early 2026 rate filings show issue-age pricing on base accident plans remaining stable, with some carriers introducing enhanced benefit options — including higher per-day hospital benefit maximums and extended benefit periods — at competitive price points. Consumers who purchased supplemental coverage more than two years ago may benefit from a comparison review, as new entrants have expanded the available benefit options at similar premium levels.
Healthcare Sharing Organization Reports Increased Claim Delays — Members Advised to Review
A mid-size healthcare sharing organization with members in Arizona reported to its membership that sharing distributions had been delayed due to lower-than-projected member contribution levels. The organization indicated that pending shares were being processed on a rolling basis but that some members with outstanding balances had experienced delays of 90–120 days. This development underscores the importance of independently verifying an organization's current financial health and sharing timeliness before enrolling — and periodically during membership. We are not disclosing the organization's name as the situation is developing, but encourage Arizona members of any sharing plan to confirm their pending claims status directly.
Medicare Advantage Star Ratings Released — Several Arizona Plans See Rating Changes
CMS released 2026 Medicare Advantage star ratings, which affect plan quality bonuses and will influence plan availability and benefit structures in Arizona for the coming year. Several plans operating in the Phoenix and Tucson metro areas saw rating changes — both increases and decreases — from prior year ratings. Star ratings reflect member experience, clinical quality metrics, and plan administration. Arizona Medicare beneficiaries enrolled in plans that saw significant rating decreases should review whether their plan's benefits have changed and whether a plan with stronger ratings and comparable benefits is available in their county.