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Twice-Weekly Briefing
Friday, September 11, 2026
Issue 260911-62
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The MOC Brief
Health policy, priced and translated for self-funded plan sponsors
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In This Edition
Five developments, and what each one means for you.
| 1. | Stop-loss renewal increases rose again in 2026, and the higher your deductible the steeper the increase. | | 2. | UnitedHealthcare pulls prior authorization off a long list of codes next month. | | 3. | A new FDA boxed warning lands on an infusion drug, and the monitoring test is rarely run. | | 4. | A study explains 91 percent of premium growth by spending, and leaves self-funded plans out. | | 5. | The FTC withdrew its 2021 guidance on health app breaches, and its breach notification rule still stands. |
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| 1 · STOP-LOSS · September 9, 2026 |
| Stop-Loss Premiums Rose 13.6 Percent at a $100,000 Deductible and 15.9 Percent at $750,000 |
| The 2026 Aegis Risk Medical Stop-Loss Premium Survey, cosponsored by the International Society of Certified Employee Benefit Specialists, reports 2026 renewal increases of 13.6 percent at a $100,000 individual deductible, rising step by step to 15.9 percent at $750,000. The International Foundation of Employee Benefit Plans posted a summary of the results on September 9, 2026. The same two deductibles rose 8.8 percent and 10.4 percent in the 2025 renewals, so the acceleration shows up at every deductible level in the survey, not just at one attachment point. The survey is in its twentieth year and covers 1,378 plan sponsors, more than 1,400,000 covered employees and more than $1.5 billion in annual stop-loss premium. Cancer remains the top claimant concern at 89 percent, down from 92 percent a year ago, with specialty pharmacy second at 57 percent. |
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MOC Perspective
Stop-loss is your fixed cost, and it is the one line you can still shop before January. The survey says the increase gets steeper as the attachment point rises, which is the opposite of what most sponsors assume when they raise a deductible to buy the premium down. A renewal quote near 15 percent is in line with what the survey reports, so the argument worth having with your carrier is not about the percentage. It is about which claims drove it and whether any of them are still on the book.
What to do now
| ▪ | Pull your 2026 stop-loss renewal and compare your increase against 13.6 percent at $100,000 and 15.9 percent at $750,000. | | ▪ | Ask your broker to quote at least two attachment points for 2027, because the survey shows the increase rising with the deductible. | | ▪ | Request your carrier's laser list and the specialty pharmacy share of your stop-loss claims before you sign, since 57 percent of sponsors named specialty pharmacy a top claimant concern. |
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| Source: International Foundation of Employee Benefit Plans, reporting the 2026 Aegis Risk Medical Stop-Loss Premium Survey |
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| 2 · PRIOR AUTHORIZATION · September 1, 2026 |
| UnitedHealthcare Will Drop 30 Percent of Its Prior Authorization Requirements on October 1 |
| UnitedHealthcare told providers on September 1, 2026 that "beginning Oct. 1, 2026, we're eliminating 30% of prior authorization requirements" across five books of business: its commercial plans, Medicare Advantage plans, Community Plans, Individual Exchange plans and Oxford plans. The company published two code lists, one for commercial and one for Oxford, each saying prior authorization "will no longer be required" for the codes it names as of that date. The lists cover genetic and molecular testing, surgical procedures, endoscopy and durable medical equipment. Neither list prints a total code count, and neither says how the change reaches plans that fund their own claims. Both carry the same instruction: "For plan-specific exceptions, continue to verify requirements through the Prior Authorization and Advance Notification tool on the UnitedHealthcare Provider Portal." |
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MOC Perspective
If UnitedHealthcare administers your plan, a utilization control you are paying for comes off next month, and your contract may or may not follow the standard list. The company's own instruction points to plan-specific exceptions, which means the answer for your plan is not on the public page. Dropping a review step cuts friction for your members, and it also stops catching the claims it used to catch. The question to put to your account team is which of these codes were actually denying anything on your plan last year.
What to do now
| ▪ | Ask your UnitedHealthcare account team before October 1 which of the two code lists applies to your plan and whether your plan carries an exception. | | ▪ | Pull your last 12 months of prior authorization denials by code and count how many sit on the list that goes away. | | ▪ | Schedule a 90-day review of utilization on the affected codes so you can price the change at renewal rather than after it. |
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| Source: UnitedHealthcare |
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| 3 · DRUG SAFETY · September 1, 2026 |
| The FDA Put a Boxed Warning on Injectafer and Says the Monitoring Test Is Rarely Done |
| On September 1, 2026 the FDA required a boxed warning on Injectafer, the brand name for ferric carboxymaltose injection, describing the risk of symptomatic hypophosphatemia and recommending phosphate monitoring "in patients at risk of hypophosphatemia and in any patient who receives a repeat course of therapy within three months of the prior course." The agency said the reaction keeps being reported "despite labeling changes in February 2020 and May 2023 adding and strengthening the warning about this risk." Its review of adverse event reports found consequences including "hospitalization, need for phosphate replacement therapy over weeks to months, and extensive monitoring with regular follow-up medical visits," and serious outcomes including osteomalacia and fractures. The figure that makes this a plan story is a testing rate: "Data from the FDA's Sentinel System indicate that serum phosphate laboratory testing occurs in fewer than 20% of ferric carboxymaltose administration episodes." The FDA names no alternative iron product and recommends no switch. |
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MOC Perspective
Injectafer is an infusion billed under the medical benefit, which is where most sponsors have the least visibility and the loosest utilization management. The FDA is not telling you to move the drug. It is telling you that a cheap lab test which prevents an expensive complication is skipped in more than four administrations out of five. One hospitalization and months of phosphate replacement cost your plan far more than the serum phosphate panel that would have caught it.
What to do now
| ▪ | Ask your medical claims administrator how many ferric carboxymaltose infusions your plan paid in the last 12 months and how many carried a serum phosphate test. | | ▪ | Add serum phosphate monitoring to your infusion site of care review before your next plan year, since the FDA recommends testing ahead of any repeat course inside three months. | | ▪ | Ask your specialty and infusion vendors for the date they updated their protocols to the September 1, 2026 labeling. |
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| Source: U.S. Food and Drug Administration |
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| 4 · PREMIUM ECONOMICS · September 4, 2026 |
| A New Study Explains 91 Percent of Premium Growth by the Growth in Health Spending |
| Zack Cooper of the Yale School of Public Health and Stuart V. Craig of the Wisconsin School of Business published a new cohort study in JAMA Health Forum dated September 4, 2026. Their data are the 2011 to 2024 Medical Loss Ratio public use files from the CCIIO at the Centers for Medicare and Medicaid Services. Across the large group market, the small group market and the exchanges, the enrollee-weighted mean premium grew 78.4 percent, or $3,143. The authors report that "91% of the growth in health insurance premiums was explained by growth in health spending," and they are precise about what that number is: an R-squared measuring cross-state variation in premium growth, which they say "is not a causal estimate." On the carrier's own cut the study points in two directions. Insurer markups "increased in dollar terms by $299 (47.6%) during this period," while falling in percentage terms from 18.6 percent to 14.9 percent. The authors also state their own limit plainly, that the data do not include premiums and health spending for employers who fund their own plans, "which cover approximately one-half of the US population." |
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MOC Perspective
The caution is the one the authors print themselves. This measures the fully insured market, so it describes the world your fully insured competitors live in and not your own claims file. Taken for what it is, it says premium growth tracked spending growth almost exactly, and that the carrier's markup shrank as a percentage while still rising by $299 in dollars. Both halves are useful to you. The claims line is where the growth lives, and the administrative line did not stand still.
What to do now
| ▪ | Rank your top 10 cost drivers by growth rather than by total spend before your planning cycle opens. | | ▪ | Ask your administrator for a three year trend split between unit price and utilization, since this study covers the fully insured market and not your plan. | | ▪ | Price your administrative cost as a share of total plan spend before your next renewal, and ask what the last three years of increases bought you. |
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| Source: JAMA Health Forum, via PubMed Central |
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| 5 · HEALTH DATA · September 9, 2026 |
| The FTC Rescinded Its 2021 Statement on Breaches by Health Apps and Other Connected Devices |
| The Federal Trade Commission announced on September 9, 2026 that it "rescinded the 2021 Policy Statement on Breaches by Health Apps and Other Connected Devices." The rescission document says the Commission determined the statement "provided minimal benefit and has been superseded by rulemaking," and cites the Health Breach Notification Rule at 89 Fed. Reg. 47028 (May 30, 2024). The announcement describes that 2024 update as covering "health apps and connected devices like fitness trackers, rendering the policy statement unnecessary." The document withdraws the statement only. It amends no rule, and the FTC's own rule library still lists the Health Breach Notification Rule at 16 CFR Part 318. Neither the announcement nor the rescission publishes a Commission vote. |
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MOC Perspective
Some of your wellness, fertility, musculoskeletal and navigation vendors sit outside HIPAA, and for those the FTC's breach notification rule is what governs the loss of member data. If a vendor contract or a security addendum cites the 2021 statement by name, that citation now points at a document the FTC has withdrawn. Repointing it costs you an afternoon of contract review, and it is the sort of gap nobody notices until there is a breach to notice it with.
What to do now
| ▪ | List every digital health vendor your plan touches and mark which are HIPAA business associates and which are not, before your next vendor review. | | ▪ | Search your vendor contracts and security addenda for the 2021 policy statement before your next renewal, and repoint any citation to 16 CFR Part 318. | | ▪ | Ask each vendor outside HIPAA, in writing and within 30 days, for its breach notification timeline and the date it last updated its breach policy. |
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| Source: U.S. Federal Trade Commission |
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The Bottom Line
Four of these five stories land on something a vendor manages for you rather than something you run yourself. Stop-loss is a fixed cost you can shop. Prior authorization is a control you rent, and part of it may be handed back on October 1 depending on what your contract says. The phosphate test is a monitoring step your infusion vendor either performs or does not, and your app vendors' breach duties come from a rule your contracts may never have named. None of it moves without someone asking, and your 2027 renewal is being priced now.
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Jude Odu
Founder and Principal, Model Optimal Care
Author of Model Optimal Care: End U.S. Healthcare Waste, One Health Plan at a Time
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