Alert Edition April 2026

Welcome to the April 2026 edition of the FORC Alert. If you have any colleagues that may be interested in this publication, please forward it on. There is a link on the Alerts main page where they can subscribe to receive FORC Alerts automatically.

Regards,
C. Ignacio Matos, Esq., FORC Alert Co-Editor
Ryan Smart, Esq., FORC Alert Co-Editor
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Category(s): - 03/31/2026

500M Records Exchanged Through TEFCA, Federal Health IT Office Boasts
“Nearly 500 million records have been exchanged through the Trusted Exchange Framework and Common Agreement (TEFCA), up by a jaw-dropping 4,900% since January 2025, the Department of Health and Human Services’ health IT office announced.” Click <a href="https://www.fiercehealthcare.com/health-tech/500m-records-exchanged-through-tefca-federal-health-it-office-boasts" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

CMS Drops States' Requirement to Report Children's Vaccination Rates
“Federal health officials are rolling back a long-standing requirement that states track and report childhood vaccination rates for children covered by Medicaid and the Children’s Health Insurance Program.” Click <a href="https://www.wusf.org/health-news-florida/2026-01-05/cms-drops-states-requirement-to-report-childrens-vaccination-rates" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

CMS Issues Final Rule Closing State Medicaid Provider Tax 'loophole'
“CMS said the tactics have generated an estimated $24 billion in revenue for just seven states, and that heading them off will save the federal government $78.2 billion over the next decade. Some of the final rule’s changes have a Dec. 31 deadline, though some states will have longer depending on the timing of their relevant tax waivers.” Click <a href="https://www.fiercehealthcare.com/regulatory/cms-issues-final-rule-closing-state-medicaid-provider-tax-loophole" target="_child">here </a> to read the full article.

Category(s): - 03/31/2026

CMS Plans to Roll Back Limits on Nonstandard ACA Plan Options
“In the proposed Notice of Benefit and Payment Parameters for the 2027 plan year, released Feb. 9, the CMS said it intends to discontinue those limits as well as requirements that plans offer standardized options on the exchanges.” Click <a href="https://www.fiercehealthcare.com/regulatory/cms-plans-roll-back-limits-non-standard-aca-plan-options" target="_child">here </a> to read the full article.

Category(s): - 03/31/2026

CMS Wants to Speed Up Tech Innovation and AI for Patients, Setting Major Goalposts in 2026
“It's been almost six months since the Trump administration unveiled a sweeping health tech initiative that aims to modernize Medicare and advance next-generation digital health for patients, including conversational artificial intelligence, digital IDs and easier ways to access health data.” Click <a href="https://www.fiercehealthcare.com/ai-and-machine-learning/cms-trying-speed-tech-innovation-and-ai-patients-major-goalposts-set-2026" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

Coalition Against Insurance Fraud Announces New Leadership Appointments
“The Coalition’s 14 committees and task forces play a vital role in advancing industry best practices, strengthening partnerships, and addressing emerging insurance fraud challenges. These leaders have been selected as co-chairs to guide strategic discussions and drive meaningful progress across the organization’s membership.” Click <a href="https://www.insurancejournal.com/news/national/2026/02/18/858466.htm" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

FCA Launches Forward-Looking Review As 'Agentic AI' Reshapes Financial Services
“The review comes amid criticism of UK regulators' approach to AI. A Treasury Select Committee report earlier this month said it does not feel confident the UK financial system is prepared for a major AI-related incident, noting that more than 75% of UK financial services firms now use AI.” Click <a href="https://www.insurancebusinessmag.com/uk/news/technology/fca-launches-forwardlooking-review-as-agentic-ai-reshapes-financial-services-563412.aspx" target="_child">here </a> to read the full article.

Category(s): - 03/31/2026

FEMA Unveils Updated Flood Maps that Could Impact Insurance Requirements
“FEMA has released draft versions of updated flood maps that could soon change flood insurance requirements for homeowners in affected communities. The updated maps, known as Pending Flood Insurance Rate Map databases, have been designated final through a Letter of Final Determination.” Click <a href="https://www.click2houston.com/news/local/2026/02/11/fema-unveils-updated-flood-maps-that-could-impact-insurance-requirements/" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

Flood Risk Intensifies as Insurance Protection Lags Across the US: Triple-I
“According to Triple-I, flooding linked to tropical systems, severe convective storms and atmospheric rivers led to substantial property losses nationwide. New York City endured repeated flash flood events, while winter storms in California delivered close to half a year’s rainfall in certain areas, prompting mudflows and damage to hundreds of homes.” Click <a href="https://www.reinsurancene.ws/flood-risk-intensifies-as-insurance-protection-lags-across-the-us-triple-i/" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

Life Insurance Application Activity Hits Record Growth in 2025, MIB Reports
“Application activity grew 6.8% in one year, 6.7% compared to 2023, and 9.8% compared to 2022, the MIB 2025 Annual Report found. It represented the highest total volume of annual application activity seen in the last 10 years.” Click <a href="https://insurancenewsnet.com/innarticle/life-insurance-application-activity-hits-record-growth-in-2025-mib-reports" target="_child">here </a> to read more. 

Category(s): - 03/31/2026

NFIP Faces Expiration as DHS Funding Stalls
“The House of Representatives passed 12 appropriations bills on Tuesday, six of which have been signed into law, according to a statement from the House Appropriations Committee. However, the DHS funding package, which includes appropriations for both NFIP and the Federal Emergency Management Agency (FEMA), has stalled in the Senate over disagreements about immigration enforcement.” Click <a href="https://f.datasrvr.com/fr1/026/41713/NFIP_faces_expiration_as_DHS_funding_stalls.pdf" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

Trump Releases Health Policy Outline
“Trump’s outline comes as bipartisan efforts on Capitol Hill to revive Obamacare subsidies that expired at year’s end are floundering. Premium payments have more than doubled for the average Obamacare customer as a result. The cost of health care and other pocketbook concerns are expected to feature prominently as midterm elections approach.” Click <a href="https://www.politico.com/news/2026/01/15/trump-health-outline-00730933?nid=0000014f-1646-d88fa1cf-5f46b4be0000&nname=inside-congress&nrid=b9f90c2d-fd9f-4cc9-bb78-40acf90abde2" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

US P&C Industry Sees Decade-High Performance in 2025, AM Best Reports
“The United States property and casualty (P&C) insurance sector recorded its strongest performance in ten years in 2025, driven by disciplined underwriting, robust pricing and investment gains, despite ongoing pressures from claim costs and liability exposure, according to credit rating agency AM Best.” Click <a href="https://www.reinsurancene.ws/us-pc-idustry-sees-decade-high-performance-in-2025-am-best-reports/" target="_child">here </a> to read the full article. 

Category(s): - 04/01/2026

Arizona Department of Insurance and Financial Institutions Issues Regulatory Bulletin 2026-02
The Arizona Department of Insurance and Financial Institutions (“DIFI”) has issued Regulatory Bulletin 2026-02, which rescinds Regulatory Bulletin 2025-03 that DIFI issued last year purporting to regulate insurance companies officering coverages that could also be issued as service contracts. By rescinding the 2025 Bulletin, it appears that DIFI is reverting back to the status quo in which insurers remain authorized to include coverages in their policies that could otherwise be offered under service contracts without having to be licensed as a service company. Click <a href="https://difi.az.gov/sites/default/files/Regulatory%20Bulletin%202026-02_Rescinding%20Regulatory%20Bulletin%202025-03%20%282%29.pdf" target="_child">here </a> to read more. 

Category(s): - 03/31/2026

Colorado Regulators Address Homeowners Insurance Risk Modeling and Rates
In the wake of catastrophic wildfire and hail events, Colorado regulators are reshaping how homeowners insurance risk is calculated and disclosed. New laws and regulatory guidance taking effect in 2026 focus on insurers’ use of predictive risk modeling, premium transparency, and consumer mitigation efforts, raising important questions about actuarial soundness and market stability. 
Following the catastrophic Marshall Fire in December 2021, Colorado homeowners experienced sudden premium increases, non-renewals, or denials of coverage tied to insurers’ wildfire risk assessments. In response, the Colorado General Assembly enacted <a href="https://leg.colorado.gov/bills/HB25-1182" target="_child">HB 25-1182 </a> (Risk Model Use in Property Insurance Policies), a law intended to standardize and bring transparency to insurers’ use of wildfire risk models in homeowners insurance.
HB 25-1182 requires insurers to incorporate advanced, data-driven risk modeling into rate development for homeowners policies and mandates greater transparency regarding how those models and risk scores are used. The law also requires insurers to account for both property-level mitigation measures (such as defensible space or fire-resistant construction) and community-level mitigation efforts in their wildfire risk assessments. In addition, the statute establishes a process through which consumers may seek recognition of mitigation actions and appeal certain underwriting or rating decisions.
To implement the law, the Colorado Division of Insurance recently issued a <a href="https://doi.colorado.gov/sites/doi/files/documents/New BULLETIN B-5.56 Guidance for Carriers Regarding Annual Written Notice to Policyholders on Risk Scores and Mitigation Discounts.docx.pdf?utm_medium=email&utm_source=govdelivery" target="_child">Bulletin </a> providing guidance on insurers’ annual written notice obligations to policyholders. The Bulletin addresses disclosure of wildfire risk scores, mitigation discounts, and appeal rights, and includes a sample notification form insurers may use to comply with the statute.

Category(s): - 03/31/2026

Citizens Property Insurance Policies Plummet in 2025
The early January policy total was the lowest since at least 2012. “Citizens was created as an insurer of last resort but saw explosive growth starting in 2020 and 2021 because of financial problems in the private market. It became the state’s largest insurer, with as many as 1.4 million customers in 2023.” Click <a href="https://www.gulfcoastnewsnow.com/article/citizens-property-insurance-policies/69928459" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

DeSantis Administration Nixes Uninsured Requirement for Kidcare Enrollment
“The CHIP state plan represents Florida’s official agreement with the federal government laying out how the program will operate. The requirement that those children go uninsured for two months has been established in Florida law since the program was created in 1998 to prevent “crowd out.”” Click <a href="https://floridaphoenix.com/2025/12/31/desantis-administration-nixes-uninsured-requirement-for-kidcare-enrollment/" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

Florida Committees Approve MGA, Litigation Funding Restriction Bills
“Florida legislative committees approved two bills this week that could impact property-casualty insurance in the state. One would put some restrictions on litigation financing and the other would force more transparency on insurers’ payments to managing general agencies.” Click <a href="https://www.insurancejournal.com/news/southeast/2026/01/30/856316.htm" target="_child">here </a> to read the full article.

Category(s): - 03/31/2026

Florida Engineers: Winds Under 110 mph Simply Do Not Damage Concrete Tiles
“With tile roofs popular across Florida, and with questionable claims about roof damage raising concerns in insurance and engineering circles, two Florida consulting engineers have offered this guide to aid engineers, attorneys, adjusters and property owners in examining wind damage to concrete tile roofs.” Click <a href="https://www.insurancejournal.com/news/southeast/2026/02/13/857977.htm" target="_child">here </a> to read the full article. 

Category(s): - 03/31/2026

Florida Insurance Costs 14.5% Lower Than Would Be Without Reforms, Report Finds
“Florida’s landmark 2022 and 2023 legislative changes have had a big impact on the state’s economy, thanks to lowered insurance costs that have freed up money for other investments and have attracted new companies to the state, says a report by an economic analysis firm.” Click <a href="https://www.insurancejournal.com/news/southeast/2026/02/12/857822.htm" target="_child">here </a> to read the full article. 

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