This summer has flown by and the kids are back in school. As Q4 and open enrollment are upon us, these are some of the summer trends that brokers can’t ignore that you may have missed and why they matter.

Between the ACA subsidy cliff, rising 2026 employer health costs, newly indexed ESRP penalties, a GLP-1–driven pharmacy spend squeeze, and a growing price-transparency crackdown, the ground is shifting fast for brokers. Below are five developments to watch, what changed, how each one hits your book.

ACA Subsidy Cliff: Extension Push Heats Up

House GOP bill introduced last week would extend the enhanced ACA premium tax credits for one year, while Senate Democrats are pressing insurers to warn members about potential premium spikes if subsidies lapse. The politics are fluid, but both chambers are now openly engaging the issue [Politico] [Axios]

Why it matters for brokers:

• Build two scenarios for Jan 1 renewals: with vs without the enhanced credits.
• Expect client questions on 2026 premiums and subsidy eligibility.
• Prep outreach lists for members most exposed to subsidy changes.

2026 Employer Health Costs: Another Big Jump

Health costs are set to climb again in 2026. Employer forecasts point to 6–7% growth even after plan changes and close to ~9% without them. The push comes from specialty pharmacy (GLP-1s included), higher utilization, and provider wage inflation. For brokers, that means earlier budget talks and a tighter playbook on plan design, funding, and vendor levers. [Reuters]

Why it matters for brokers:

• Socialize plan-design trade-offs early (networks, steerage, site-of-care).
• Pair cost control with behavioral health access and COE programs to avoid false savings.
• Use trend data to justify multi-year funding strategies (level-funded, captives, stop-loss optimizations).

Employer Mandate (ESRP) Penalties: 2026 Amounts Updated

As shared in the newsletter last month, the OBBBA is causing some big industry shake ups. The IRS indexing lifts the Affordable Care Act §4980H employer shared-responsibility penalties for 2026 to $3,340 (a-penalty) and $5,010 (b-penalty) per affected employee. [Thomson Reuters Tax]

Why it matters for brokers:

• Re-run pay-or-play models for ALEs; small affordability misses get more expensive.
• Tighten measurement & offers (95% rule, dependents) and validate affordability safe harbors.
• Align with payroll/HRIS on Form 1095-C data quality to avoid Letter 226-J surprises.

GLP-1 Whiplash + Pharmacy Trend: Cost Pressures Are Real

GLP-1s are now the top pressure point in pharmacy trend. Employers report pharmacy at roughly 24% of total spend, with Rx costs projected to rise 11–12% into 2026. At the same time, coverage is tightening—TRICARE For Life ended coverage for obesity-only GLP-1s as of Aug 31. This is a signal that more plans may add guardrails like prior auth, step therapy, or outcomes programs. Expect continued volatility in access, cost, and member expectations.[Business Group on Health ]

Why it matters for brokers:

• Prepare GLP-1 coverage grids (obesity vs diabetes indications, PA rules)
• Negotiate transparent PBM contracts (guaranteed net cost, audit rights, utilization levers)
• Educate members on clinical eligibility + alternatives (i.e weight-management programs, Centers of Excellence) to manage demand responsibly.

Price Transparency Crackdown: Fines & New Mandates Proposed

A bipartisan Senate bill—the Patients Deserve Price Tags Act—would codify hospital price transparency rules, raise non-compliance penalties, expand requirements to other sites of care, and push payers to offer real-time cost tools for members. [Health Leaders Media]

Why it matters for brokers:

• More usable price data supports steerage strategies (HPCNs, COEs, ambulatory migration)
• Real-time OOP tools improve member decision-making and your client reporting.
• Watch for plan & PBM disclosure duties that may add to employer fiduciary work.