New Hampshire Insurance Department Bulletin INS 26-051-AB, issued August 13, 2026, is a quiet but detailed piece of regulatory guidance that matters well beyond New Hampshire. The bulletin clarifies minimum attachment point requirements under RSA 415-H, the state’s stop-loss insurance statute: for employer groups with 51 or more covered employees, the aggregate stop-loss attachment point must be no less than 110% of expected claims, calculated using an actuarially supported methodology and certified annually by the issuing carrier by March 15.
The requirements for smaller groups are tighter. For groups of 50 or fewer, the aggregate attachment must equal the greatest of 120% of expected claims, $6,200 per covered life, or $31,000. The individual (specific) stop-loss minimum remains $31,000 per covered individual per policy year.
None of those thresholds are surprising. What the bulletin does that most state guidance does not is define what “actuarially supported expected claims” means in practice: expected claims must reflect a forward-looking trend adjustment, not a carry-forward of prior-year experience. Carriers must document their methodology, maintain support for the calculation, and certify compliance annually. That certification requirement is the lever a plan sponsor can pull.
Who it affects
Self-funded employer groups operating in New Hampshire, and any plan sponsor or captive-fronted health program with a New Hampshire stop-loss carrier. The broader audience is every self-insured employer regardless of state: New Hampshire’s articulation of methodology standards is the clearest state-level benchmark published in 2026 for what a sound expected claims calculation should include, and it is worth comparing against what your carrier is doing at renewal.
The reserve mechanism
The aggregate attachment point is the ceiling on the employer’s retained claim liability for the policy year. If that ceiling is calculated from understated expected claims, the employer is exposed above the stated attachment before the stop-loss carrier is obligated to respond.
The mechanism is direct. A carrier applies a trend rate to prior-year experience to produce the current year’s expected claims figure. That figure is multiplied by 110% to set the attachment point. If the trend rate is too low, expected claims are understated, the attachment is set too low, and the plan sponsor carries unhedged retained exposure in the corridor between the stated aggregate and what a correctly calculated 110% floor would require.
In a 9% to 12% medical cost trend environment, consistent with current benchmarks from PwC’s 2027 medical cost trend report and Segal’s 2026 stop-loss benchmarking, a carrier using a 5% to 6% trend assumption can satisfy the 110% floor on paper. On a $10 million plan, a 4-point gap in trend assumptions generates roughly $400,000 in understated expected claims. At 110%, the difference in attachment point protection is $440,000 that the plan sponsor does not know it is retaining.
This exposure does not appear on the face of the stop-loss contract. It lives inside the carrier’s expected claims calculation, which is not routinely shared at renewal.
What this means for your next review
Ask your stop-loss carrier, at this renewal, what trend rate they used to calculate expected claims and how that compares to current medical inflation benchmarks from PwC, Segal, or your independent actuary. If they cannot produce a documented methodology, that is itself the answer. New Hampshire’s certification requirement gives plan sponsors in any state a reasonable template for what to request: a written actuarial basis for the expected claims figure, not just the number. For context on how unhedged stop-loss retained exposure surfaces in your IBNR estimate, see Stop-Loss Lasering Leaves Self-Insureds With Unhedged IBNR.