Renewal season has a rhythm and most of us know it by feel. What’s different this year is that some of the dates moved, a few of the numbers came in higher than expected, and the window to do anything about either one is shorter than usual.
 

September is the last month where you can still change the outcome of a January 1 renewal. October is execution. This issue covers what to finish before October 1: how to quote 2027 before individual market rates are final, the compliance dates that are already locked, and the piece almost everybody starts too late. None of it is hard, and every week you give yourself makes it easier.

Aon projected on August 20 that employer health costs will rise 9.5% in 2027, pushing average cost past $19,000 per employee. That’s four years running near double digits, and your clients are seeing the early version of those numbers right now.

 

On the individual market side, KFF’s updated analysis of 276 insurers across all 50 states and DC puts the median proposed 2027 increase at 15%, with most proposed changes landing between 10% and 25%.

Neither set of numbers is final. You can quote now anyways if you understand realistic ranges.

When a carrier files a requested rate range, we price toward the top of what they asked for and put a conservative 2027 projection in front of the client now. A client who budgets against the worst case and gets better news in October will trust the next number you hand them. A client who sees a first number in November is picking between two bad options under a deadline.

Pull your January renewals and put every client in one of three buckets: 
1) clients who’ll absorb the increase 

2) clients who’ll complain and stay

3) clients who’ll shop

That third bucket is the only place where a September conversation and a November conversation produce different outcomes.

 

For a January 1, 2027 plan year, the ICHRA notice has to reach every eligible employee at least 90 days before the plan year begins, which puts the deadline on October 3. The Department of Labor publishes a model notice you can adapt. Employees who become eligible mid year get their notice no later than the date coverage can start.

The 2027 affordability percentage is 10.22%, up from 9.96%. For plan years beginning January through June 2027, the federal poverty line safe harbor works out to $135.92 per month for self only coverage. ICHRA affordability runs off the lowest cost silver plan in the employee’s rating area minus the allowance, so every rate change moves the math on an allowance somebody set months ago.

Recalculating in September gives you room to use. Recalculating in December just confirms a number your client already committed to.

 

CMS finalized a rule shortening the federal platform window to November 1 through December 15. A judge vacated that provision in June and the case is under appeal. Most states are expected to run through January 15, but December 15 still controls January 1 effective dates everywhere. Confirm your state exchange dates before you put a timeline in writing for a client.
 

The HRA Council’s Volume 5 report, out August 12, found that more than 20,000 US businesses now offer an ICHRA as their primary health benefit, a 53% jump from 2025, with applicable large employers as the fastest growing segment. More than half of enrollments come from workers under 45, and most of them choose silver or gold plans.

Read that behavior for what it is. Those employees are making an active purchase decision, comparing networks and premiums and deciding how much of their own money to add. The group enrollment playbook was never built to support that process, which is why the same three questions flood HR every January.
 

What actually works is real decision support, a licensed person an employee can call, and materials drafted before the November crush instead of during. All three are September work.

 

The ICHRA Ancillary Checklist we published this spring runs 12 items across enrollment setup, employee experience, HR and administration, and open enrollment coordination. That last section is the one worth pulling back up this month.
 

Dental, vision, life, and voluntary benefits don’t move themselves when a client comes off group, and the week before enrollment opens is a bad time to discover nobody owned the question.

If any of this connects to a conversation you’re already having, or one you’ve been putting off, reach out. We’ll give you a straight answer about fit and timing, including the times the honest answer is that the timeline doesn’t work.

 Andy Stein | Founder & President