California’s Managed Care Organization (MCO) tax is imposed on health plans to help finance the Medi-Cal program. New federal rules require the Department of Managed Care to change the tax structure beginning in 2027, and this change is expected to have an impact on employer health plan premium costs.
How the Tax Evolved
California has used an MCO tax since 2009 to provide funding for Medi-Cal and to secure federal matching funds. The tax has been revised several times to comply with federal requirements, and tax rates have generally increased over the years to generate additional revenue for Medi-Cal.
In 2027, the tax is changing again to reflect new federal restrictions that prohibit state provider taxes from charging Medicaid plans more than commercial health plans (otherwise placing a disproportionate burden on Medicaid enrollment). For context, the 2025 tax was approximately $274 per month for Medi Cal managed care plan enrollment compared with $2 per month for commercial health plan enrollment.
Federal regulations issued in February 2026 provided a transition period for California’s existing arrangement through December 31, 2026, so a new tax structure is required as of January 1, 2027.
Core Tax Structure
- Rate: $8.85 per enrollee per month, across Medi-Cal managed care plans, fully insured commercial plans regulated by the Department of Managed Health care, and ACA marketplace plans.
- Timeline: Operative for calendar years 2027, 2028, and 2029.
- Effective Date: January 1, 2027, or upon federal approval, whichever is later.
- Implementation: The final rate, timing, and mechanics remain subject to federal review and state implementation.
Potential Impact on Employer Health Plans
- HMO plans. Employers with managed care plans (typically HMOs that are regulated by the CA DMHC) can expect to see an impact. Although carriers owe the tax, they will reflect it as a passthrough cost in renewal calculations. At the stated rate, the tax equals approximately $106 per enrolled member annually. For example, the tax cost for 500 covered employees and dependents would be approximately $53,000 if fully passed through. Actual pricing will depend on carrier methodology, enrollment definitions, and the final approved rate.
- PPO Plans. Traditionally, the California Department of Insurance (DOI) regulates fully insured PPO plans, thus the MCO tax does not apply to these plans. However, plans governed by the DOI are subject to the 2.35% premium tax in California.
- Self-funded plans. The tax does not apply to self-funded plans. However, employers should be aware of the application to any HMOs which may be offered alongside a self-funded plan.
- Indirect Effects. Indirect effects may potentially arise if the MCO tax influences provider reimbursements, network negotiations, or broader California health care pricing.
Employer Action Items
Employers should be aware of this change and consider factoring the restructured MCO tax into 2027 health plan budgeting and renewal discussions.
That said, since final approval is still pending, carriers are unable to make definitive determinations regarding the impact on premiums. Some carriers are projecting costs based on the currently proposed tax structure. Others are taking a wait-and-see posture.
The team at Vita is watching this closely and will provide further updates as they become available.
