Does the rule apply if I am fully insured?
The law-firm summary reports that fully insured plans are excluded from the detailed requirements. Your carrier’s own filings and DIFS review still apply to the rate.
Fully insured plans
The law-firm summary reports that fully insured plans are excluded from the detailed requirements of the rule. For a fully insured plan the carrier carries the claims risk and sets the pharmacy arrangement.
The rate for a fully insured small group plan is still subject to filing with DIFS, and large group HMO rates are filed and approved. Your renewal is where the carrier’s pharmacy trend shows up.
What a fully insured employer should still ask
According to the law-firm summary we reviewed, fully insured plans are excluded from the detailed requirements of the rule. That does not mean pharmacy pricing is irrelevant to you; the carrier’s own pharmacy arrangements are built into your premium.
Ask your carrier how pharmacy costs are reflected in the renewal, whether the pharmacy benefit manager is the carrier’s own, and what you can see about trends. We can read the answers against alternatives from other carriers.
Where to go from here
Read your renewal against the average
Separate trend from your own claims experience.
Check your network and plan type
Confirm who is in and out before you compare prices.
Send us your renewal
Share the renewal and plan documents and we will tell you what to test.
More questions on this topic
Does the rule apply to my level-funded plan?
It depends on how the plan is structured and its size.
When should a Michigan employer act?
The reported applicability date is plan years beginning on or after July 1, 2027.
Where these details come from.
Details are from the Michigan DIFS, the Department of Labor’s announcement and a law-firm summary, as of publication. Check the rule text for dates and thresholds.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.