2027 Disclosure and Insurability: Preparing for Renewal

As the 2027 renewal cycle approaches, high-cost claims, specialty drugs, biologics, and gene and cell therapies are increasing claim volatility and making timely, accurate disclosure more important than ever. Summit Re partners with clients to conduct a thorough disclosure review while minimizing disruption to their organizations.

 Disclosure is a critical final step in securing reinsurance, medical excess, or provider excess coverage, which protects the insurer or provider from catastrophic claims. It captures claimant information that may have emerged after underwriting began but before coverage is bound, helping ensure that final terms reflect the most current risk profile. The review focuses on the latest claim, pharmacy, utilization management, and care management activity available when the coverage binder is signed.

Why is disclosure important?

When preparing a quote for coverage, the reinsurer performs a careful analysis of reinsurance claim costs and trends, including current-year claim activity, emerging large claims, pharmacy experience, specialty drug utilization, and known or anticipated high-cost therapies. A critical assumption is the degree to which this data can be considered complete. Disclosure helps the reinsurer validate the accuracy of this assumption before final terms are confirmed.

 The disclosure identifies claimants with high-cost, chronic, or predictable utilization and costs. For 2027, this includes complex inpatient, neonatal, transplant, oncology, and chronic-condition claims, as well as specialty drugs, biologics, and gene and cell therapies that may create concentrated, multi-million-dollar exposure. If possible, Summit may recommend a cost reduction or care management strategy to assist you in managing these claimants. In some cases, this strategy may include the common practice of “lasering” some members by placing higher deductibles on these individuals or excluding them from coverage if a reinsurance claim is already anticipated.

 Accurate disclosure helps protect you from the possible denial of a reinsurance claim. Because the disclosure statement becomes part of the signed binder and, ultimately, the policy or agreement, the reinsurer may exclude a serious loss that the client knew or should have known about but did not disclose when the binder was signed.

What to disclose?

The disclosure statement outlines the information required for the 2027 underwriting review. To expedite the process, provide Summit Re with information limited to individuals who represent a potential serious loss, including every such individual known to you or any delegated authority. Confer with your utilization management, case management, pharmacy, transplant, specialty drug, and complex care teams because they may have received a recent request for high-cost care, specialty medication, gene or cell therapy evaluation, transplant services, facility admission, or other treatment not yet known to the finance and claims departments.

What are the possible outcomes?

In most cases, disclosure confirms a normal level of acute catastrophic claim activity, allowing the reinsurer to confirm the terms as originally priced.

Another possible outcome is the identification of a significant claim that is highly likely to continue into the 2027 coverage period or a member who is a known candidate for an identifiable high-cost therapy. If the claim is likely to exceed the retention, a separate deductible may be assigned. Because the claim and its expected costs are then known to both you and the reinsurer, they may be considered uninsurable under the basic reinsurance principle that known events with predictable costs are not insurable.

A third possible outcome occurs when the disclosed claim information differs materially from the information presented during the quotation process. In that circumstance, the reinsurer may revise the quoted rates or terms or withdraw the quote. Summit Re works closely with clients throughout disclosure to minimize the likelihood of this outcome.

The following applicant disclosure statement summarizes the information required to complete the disclosure review and will support underwriting decisions.

Disclosure Statement by Applicant

This Applicant Disclosure Statement (“Disclosure”) must be completed by the Applicant and returned to Summit Re.  Completion and execution of this Disclosure by an authorized officer of the Applicant, is a warranty that a diligent review for potential Serious Losses was completed by consulting with your administrator, utilization review, case management, pharmacy, and claims unit(s), either internally or from any delegated authority, to review claim information including, but not limited to pre-certification, medical and pharmacy information, disability and/or utilization review data, case management records, hospital inpatient logs and transplant waiting list(s). Further, as part of any Disclosure it is the Applicant’s duty to provide current information for Members who may have been included in the information exchange during the underwriting process and who meet the definition of Serious Losses at the time of signing the Offer.

Serious Losses mean any potential Member expected to incur claims that may reasonably be assumed will reach seventy-five percent (75%) of the Specific Retention in the current or the upcoming Agreement Period based on their:

  1. primary diagnosis or diagnoses, if significant co-morbidities;

  2. current physical condition, treatment plan, prognosis, and facility confinement status (e.g. acute hospital, long term acute care, skilled nursing facility, etc.);

  3. referral for or undergoing a transplant evaluation;

  4. potential for receiving specialty drugs (oral, injectable, or infusion), gene and cell therapies, blood factor products or blood derivatives, including those that are covered under the medical benefit; or

  5. chronic high-cost treatment, planned surgeries, and prolonged facility admissions.  “Chronic” shall mean the illness, condition or disease is continuing or occurring again and again for more than three (3) months.

Serious Losses known by the Applicant, either internally or from any delegated authority such as an administrator, pharmacy benefit manager, utilization review or case management company, as of the date the Offer is executed, will be excluded from coverage unless fully Disclosed to and accepted by Summit Re.

Disclose or Disclosed means the following information has been provided to Summit Re:

1.           A paid claim detail report of all Members who have exceeded fifty percent (50%) of the Specific Retention for the current Agreement Period;

2.           A report for all Members considered Serious Losses, which contains the following:

a.           Member ID/Name (or other unique identifier) and date of birth;

b.            Admission date and estimated discharge date, if applicable;

c.            Diagnosis, current status, and treatment plan;

d.           Expenses incurred to date & estimated expenses to be incurred/paid within the Agreement Period;

e.            Anticipated hospital admissions or planned surgeries that have potential to exceed the Specific Retention; and

f.             For each Member identified as receiving, or having the potential to receive, specialty drugs (oral, injectable, or infusion), blood factor products or blood derivatives including those covered under the medical benefit:

i.             Whether the Member is receiving the drug or product prophylactically or on an as needed basis;

ii.            Drug or product name, dosage, frequency and cost per treatment;

iii.          Expected duration of treatment;

iv.           Site of administration (i.e. inpatient, outpatient, physician office, home, self-administered); and

v.            Response to additional questions on the attached document entitled “Summit Re Underwriting Questions: High-Cost Therapies”.

Preparing for a Successful 2027 Disclosure

A timely and complete disclosure helps protect your organization, supports informed underwriting decisions, and reduces the risk of unexpected coverage limitations or claim denials. Early coordination among claims, pharmacy, utilization management, case management, and other delegated partners is essential to identifying serious losses before coverage is bound. Summit Re is committed to working with you throughout the process to clarify requirements, evaluate emerging risks, and help secure appropriate coverage for the 2027 agreement period.

Article by Kathy Clark, RN, BSN, CMCN, RIT, Vice President, Director of Managed Care. For more information about how the impact on your plan, please contact your Summit ReSources care specialist.

FDA Approves Gene Therapy for Treatment of Spinal Muscular Atrophy

[From FDA.gov]

For Immediate Release:

November 24, 2025

The U.S. Food and Drug Administration today approved Itvisma (onasemnogene abeparvovec-brve) for the treatment of spinal muscular atrophy (SMA) in adult and pediatric patients 2 years of age and older with confirmed mutation in the survival motor neuron 1 (SMN1) gene. Itvisma is an adeno-associated virus (AAV) vector-based gene therapy.

“Today’s approval shows the power of gene therapies and offers treatment to patients across the SMA disease spectrum, including patients at various ages, SMA symptoms, and motor functional levels,” said Vinay Prasad, M.D., M.P.H., the FDA’s Chief Medical and Scientific Officer and Director of the Center for Biologics Evaluation and Research. “This exciting area of science continues to change the lives of patients and the FDA is committed to expediting the development of products for unmet medical needs.”

SMA is an autosomal-recessive neurodegenerative disorder caused by mutations in the SMN1 gene, characterized by irreversible and progressive motor neuron loss, leading to progressive muscle atrophy and weakness, and subsequent paralysis and death in the most severe cases. SMA has an incidence of approximately 4-10 per 10,000 live births. Prior to the availability of effective treatment, SMA was considered one of the leading causes of infant mortality due to genetic disease in the U.S.

Itvisma demonstrated substantial evidence of effectiveness for the treatment of SMA in pediatric patients 2 years of age and older with a confirmed mutation in the SMN1 gene based on primary evidence of effectiveness from the adequate and well controlled Phase 3 study,  and the confirmatory evidence of effectiveness from data characterizing the mechanism of the product’s action, as well as efficacy findings from Zolgensma (onasemnogene abeparvovec-xioi) which contains the same active ingredient in an intravenous formulation. The applicant provided adequate justification to support expanding the indication beyond the pivotal study population to include adult patients with SMA, however, warnings and precautions are warranted due to the potentially increased risks of adverse events of special interest (e.g., hepatotoxicity and cardiotoxicity) in adult patients with preexisting chronic medical conditions.

The active ingredient (drug substance) in Itvisma is identical to Zolgensma but formulated at a different concentration. Zolgensma is administered intravenously based on patient weight to pediatric patients less than 2 years of age with SMA due to bi-allelic mutations in the SMN1 gene. Itvisma is a concentrated formulation in a smaller delivery volume, administered directly to the central nervous system via a single intrathecal injection independent of patient weight, which expands treatment options available to patients with SMA older than 2 years of age.

The direct administration of Itvisma into the cerebrospinal fluid surrounding the spinal cord (site of action) allows for delivery to motor neurons with a lower dose of vector, without the need to adjust for the patient’s body weight. This provides a treatment with rapid onset and direct targeting of the genetic root cause of SMA. By addressing the root cause of SMA, Itvisma restores SMN protein production and halts further disease progression.

The FDA review team worked collaboratively to leverage Zolgensma safety data and most of the side effects of Itvisma are consistent with identified risks associated with Zolgensma. Information from the hepatotoxicity boxed warning in the Zolgensma label is retained in the Itvisma label with appropriate modifications. This approach is supported by clinical data showing hepatotoxicity in Itvisma clinical studies.

“Significant unmet need remains in SMA, particularly for patients across various ages and motor function levels, predominantly those 2 years of age and older.” said Vijay Kumar M.D., Acting Director, Office of Therapeutic Products in the FDA’s Center for Biologics Evaluation and Research. “This approval shows our continued commitment to supporting and facilitating treatments for patients with rare diseases.”  

The FDA granted this application Fast Track, Breakthrough Therapy, and Priority Review designations. Itvisma also received Orphan Drug designation, which provides incentives to encourage the development of drugs for rare diseases. Itvisma is manufactured by Novartis Gene Therapies, Inc.

FDA Approves New Safety Warning and Revised Indication that Limits Use for Elevidys Following Reports of Fatal Liver Injury

[From FDA.gov]

For Immediate Release:

November 14, 2025

The U.S. Food and Drug Administration today announced it is taking action to approve new labeling submitted by the company that includes the addition of a Boxed Warning, the agency’s most prominent safety warning, to Elevidys (delandistrogene moxeparvovec-rokl), and that the indication section of the labeling limits the therapy’s indication to ambulatory patients four years of age and older with Duchenne muscular dystrophy (DMD). These actions follow reports of fatal acute liver failure in non-ambulatory patients treated with the product.  

Elevidys is an AAVrh74 adeno-associated virus (AAV) vector-based gene therapy approved for the treatment of DMD in certain patients. In June 2025, the FDA issued a CBER Safety Communication following two reports of fatal acute liver failure in non-ambulatory pediatric males with DMD after receiving Elevidys. In response, the manufacturer voluntarily paused distribution of Elevidys for use in non-ambulatory patients.  

In both fatal cases, patients developed markedly elevated liver enzymes and required hospitalization within two months of Elevidys infusion. An additional serious, non-fatal case of acute liver injury has involved complications such as mesenteric vein thrombosis, bowel ischemia and necrosis, and portal hypertension.  

After a comprehensive evaluation of the available safety data, FDA has now approved substantial labeling revisions for Elevidys, including:  

  • Addition of a Boxed Warning describing the risk of serious liver injury and acute liver failure, including fatal outcomes;  

  • Limiting the indication to ambulatory patients with DMD who are 4 years of age and older with a confirmed mutation in the DMD gene;  

  • Removal of the indication for non-ambulatory patients with DMD;  

  • Addition of a Limitations of Use statement to guide clinical decision-making;  

  • Updates to the Warnings and Precautions, Dosage and Administration, Adverse Reactions, Use in Specific Populations, Clinical Studies, and Patient Counseling Information sections; and  

  • Inclusion of a new Medication Guide for patients and caregivers.  

Key Safety Information for Patients and Health Care Providers  

The revised labeling includes specific safety information and monitoring recommendations:  

  • Liver monitoring: Weekly liver function tests are advised for at least three months after treatment. Patients should remain near an appropriate medical facility for at least two months post-infusion.  

  • Prompt medical attention: Patients should contact their health care provider immediately if they experience yellowing of the skin or eyes, if they miss or vomit corticosteroid doses, or if the patient experiences a change in mental status.  

  • Infection risk: Corticosteroid therapy may suppress immune function, increasing susceptibility to infections and serious complications including death.  

  • Cardiac monitoring: Weekly testing for cardiac injury (troponin-I) is advised for one month following treatment.  

  • Contraindications: Elevidys should not be used in patients with deletions involving DMD exons 8 and/or 9.   

  • Limitations of Use: Elevidys is not recommended in patients with preexisting liver impairment, recent vaccinations, or recent/active infections.  

Postmarketing Requirements  

The FDA is requiring the manufacturer to conduct a postmarketing observational study to further assess the risk of serious liver injury. The study will enroll approximately 200 patients with DMD and follow them for at least 12 months after administration of Elevidys, with periodic liver function assessments.  

Reporting Adverse Events  

Health care professionals and patients are encouraged to report adverse events, including cases of liver injury, to the FDA MedWatch program:  

Adverse events may also be reported to Sarepta Therapeutics, Inc. at 1-888-727-3782.  

The FDA remains committed to the continued evaluation of the safety and effectiveness of gene therapies and will provide updates as new information becomes available. 

FDA Approves Tecelra, First T Cell Therapy for Solid Tumors

On August 2, 2024, the FDA granted accelerated approval for Tecelra (afamitresgene autoleucel) a melanoma-associated antigen A4 (MAGE-A4)-directed genetically modified autologous T cell immunotherapy indicated for the treatment of adults with unresectable or metastatic synovial sarcoma who have received prior chemotherapy, are HLA-A*02:01P, -A*02:02P, 16 -A*02:03P, or -A*02:06P positive and whose tumor expresses the MAGE-A4 antigen as determined by FDA-approved or cleared companion diagnostic devices. Tecelra is contra-indicated in adults who are heterozygous or 52 homozygous for HLA-A*02:05P.[i]

Synovial sarcoma is an uncommon and aggressive cancer that can form in soft tissues such as muscles, fat, joint linings, and ligaments. It is often found in the arm, leg, or foot, and near joints such as the wrist or ankle. It can also form in soft tissues in the lung or abdomen. Although synovial sarcoma can affect people at any age, it is known to occur more commonly in adolescents and adults younger than 30.[ii] Adults with metastatic synovial sarcoma at diagnosis have a 5-year overall survival rate of 10%, versus 76% for those with localized disease at diagnosis.[iii]

Synovial sarcoma (SS) accounts for up to 10% of all soft-tissue sarcomas. In the US, 800-1000 new cases of SS are diagnosed annually. According to an analysis of the Surveillance, Epidemiology, and End Results (SEER) database study, the age-adjusted incidence rate of SS in the US is 0.177 per 100,000 (approximately 580 incident cases) with a prevalence rate of 0.65 per 100,000 (approximately 2129 prevalent cases).[iv]

Tecelra is an autologous T cell immunotherapy composed of a patient’s own T cells. T cells in Tecelra are modified to express a TCR that targets MAGE-A4 expressed by cancer cells in synovial sarcoma. After the patient undergoes leukapheresis, cells are sent for manufacturing. It takes about six weeks for the Tecelra to be returned to the provider, though that time may vary.

The patient is admitted to the hospital and receives a lymphodepleting chemotherapy regimen of fludarabine 30 mg/m2/day intravenously for four days starting on the seventh day before Tecelra infusion (Day-7 to Day -4), and cyclophosphamide 600 mg/m2/day intravenously for 3 days starting the seventh day before Tecelra infusion (Day -7 to Day -5).  Tecelra is administered over an hour as a single intravenous infusion on Day 1.  The patient will remain hospitalized for at least seven days after the infusion. The patient should plan to stay close to a healthcare facility for at least four weeks.[v]

The safety and effectiveness of Tecelra were evaluated in a multicenter, open-label clinical trial. Effectiveness was evaluated based on overall response rate and the duration of response to treatment with Tecelra. Among the 44 patients in the trial who received Tecelra, the overall response rate was 43.2% and the median duration of response was six months. Tecelra was approved under an accelerated approval pathway and a confirmatory trial is ongoing to verify Tecelra’s clinical benefit.[vi]

A Black Box Warning has been issued because patients may experience cytokine release syndrome. Patients may also exhibit Immune Effector Cell-associated Neurotoxicity Syndrome (ICANS).

The current list price for  Tecelra is $727,000. This does not include the pre-treatment or hospitalization costs associated with the administration of the therapy.

Article by Kathy Clark, RN, BSN, CMCN, Vice President, Director of Managed Care. For more information about how this may affect your plan, please contact your Summit ReSources care specialist. The following sources were used as reference material for this article:

[i] FDA Package Insert-Tecelra. https://www.fda.gov/media/180565/download?attachment. Accessed 8/12/2024.

[ii] National Cancer Institute. Synovial Sarcoma. https://www.cancer.gov/pediatric-adult-rare-tumor/rare-tumors/rare-soft-tissue-tumors/synovial-sarcoma#:~:text=Synovial%20sarcoma%20is%20a%20cancer,also%20be%20called%20malignant%20synovioma. Accessed 8/12/2024.

[iii]Blay JY, von Mehren M, Jones RL, Martin-Broto J, Stacchiotti S, Bauer S, Gelderblom H, Orbach D, Hindi N, Dei Tos A, Nathenson M. Synovial sarcoma: characteristics, challenges, and evolving therapeutic strategies. ESMO Open. 2023 Oct;8(5):101618. doi: 10.1016/j.esmoop.2023.101618. Epub 2023 Aug 23. PMID: 37625194; PMCID: PMC10470271. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10470271/ Accessed 8/12/2024.

[iv] Mangla A, Gasalberti DP. Synovial Cell Sarcoma. [Updated 2023 May 6]. In: StatPearls [Internet]. Treasure Island (FL): StatPearls Publishing; 2024 Jan-. https://www.ncbi.nlm.nih.gov/books/NBK587366/. Accessed  8/12/2024.

[v] FDA Package Insert-Tecelra. https://www.fda.gov/media/180565/download?attachment. Accessed 8/12/2024.

[vi] FDA. FDA Approves First Gene Therapy to Treat Adults with Metastatic Synovial Sarcoma. https://www.fda.gov/news-events/press-announcements/fda-approves-first-gene-therapy-treat-adults-metastatic-synovial-sarcoma. Accessed 8/12/2024.