Ryan Smith is the Senior Solutions Advisor for True Insurtech Solutions
Workers’ compensation is a federation, not a system. The closing session of AIS 2026 made that case more clearly than any panel in recent memory. NCCI President and CEO Tracy Ryan, WCIRB President and CEO Andrea Coleman, and NYCIRB President and CEO Jeremy Attie sat together on stage in Orlando and described three jurisdictions navigating overlapping forces with different tools, different speeds, and different stakeholders.
The takeaway for any carrier with a multi-state footprint was simple. You cannot run the same book the same way across these three markets, and the data is now sharp enough to prove it. Donna Glenn’s cross-state themes session earlier in the week set the analytical groundwork. The three-CEO panel translated it into the practitioner-level conversation about how the rating organizations are actually responding to the forces shaping their respective markets. We covered the pre-conference outlook on these CA, NY, and NCCI dynamics earlier in this series, and the rest of the pre-conference coverage lives on our AIS 2026 Resource Hub.
The DWP Picture Told You Most of the Story Before Anyone Spoke
If you only looked at the 2025 direct written premium figures NCCI shared at State of the Line, you already had a clear preview of what each leader was going to say. The three blocks moved in three different directions in 2025.
- NCCI states posted $25.6 billion in DWP for 2025, a decrease of 2.0% from 2024.
- California posted $10.8 billion, an increase of 1.6%.
- New York posted $3.2 billion, a decrease of 6.8%.
Three different trajectories in a single year, none of them tracking the national headline of -0.2% net written premium change.
Together, these three blocks account for the overwhelming majority of U.S. workers’ compensation premium volume. NCCI states represent 51% of share. California represents 21%. New York represents 6%. For carriers operating across more than one of these blocks, the divergence is not just statistical. It is the daily reality of running underwriting, claims, and compliance operations against three different trajectories. And the gap between them is widening, not narrowing.
California: Cumulative Trauma Is a Category of Its Own
California’s premium grew while most of the country’s contracted. That is the headline. The story underneath it is more interesting.
Andrea Coleman, who took over as President and CEO of the WCIRB in 2025, has used her first year to focus on data infrastructure and emerging-trend identification. Her quoted framing from the panel was direct: she described the WCIRB’s work as integrating new data elements into its analytics to better identify emerging trends, and noted that the work would be strongest through continued partnership and collaboration across the bureaus and NCCI going forward.
The data point that most clearly captures why California is its own market is cumulative trauma. NCCI’s cross-state themes data showed cumulative trauma as a share of total claim counts running at roughly 22% in California for accident years 2022 through 2024. In NCCI states, the share is below 6% across the board. That is not a small gap. It is a fundamentally different claim composition that affects severity, duration, attorney involvement, and reserving assumptions in ways no national average can absorb.
California’s combination of premium growth, cumulative trauma concentration, and an active bureau modernization agenda makes it the most operationally distinct of the three blocks. For any carrier with California exposure, that single data point should reframe how you read national benchmarks. Your California book is not a slightly different version of the national book. It is a different book, shaped by different injury patterns, different claim handling realities, and a bureau filing cycle that responds faster to emerging data than the annual NCCI cadence allows.
New York: Falling Premium, Rising Strategic Questions
New York’s -6.8% DWP change was the steepest of the three major blocks in 2025. That premium decline is the visible part. The forward-looking part is where Jeremy Attie spent most of his time.
Attie described “three major shifts” worth tracking. “Increasing automation that may reduce human involvement, the long-term evolution of remote work beyond its pre-COVID limitations, and the rapid adoption of AI as a driver for industry innovation.“
Each of those three shifts plays out differently in New York than in NCCI states or California. New York’s benefit structure, broad coverage requirements, and concentration of professional services and office employment make automation and remote work particularly relevant to how exposure evolves. The state’s premium volume is sensitive to office-class employment patterns in ways that NCCI’s national average does not fully capture, and Attie’s emphasis on those forward-looking trends puts a clear marker on the strategic agenda for any carrier with material New York exposure.
Attie also flagged the NYCIRB’s continued investment in data infrastructure, including the kind of indemnity and medical data call participation expansion that produces sharper insight into emerging trends. The implication for carriers is that the analytical bar for understanding New York is rising. Bureau-level data is getting more granular, and the carriers and administrators able to consume that granularity in their own systems will have a real advantage in pricing and claims strategy.
NCCI States: Favorable, but Pulling in Different Directions
The 38 states where NCCI provides ratemaking services delivered a 2026 average loss cost level change of -5.0%. That sounds uniform on the surface. The range within that average is anything but.
The most recent voluntary-market loss cost changes (excluding law-only filings) ranged from -15.6% in New Mexico to +22% in Nevada. Most NCCI states clustered in the -3% to -8% band, but the tails are wide and they matter. A 37-point spread between the high and low ends of an annual filing cycle is the kind of variation that should change how multi-state pricing strategies get built.
Donna Glenn’s cross-state themes session covered the specific actions NCCI has taken in response to state-level dynamics. Glenn called out two examples directly. The Nevada law-only filing effective October 1, 2026, was premium-neutral overall, but it raised the payroll cap from $36,000 to $98,000 and redistributed responsibility across stakeholders accordingly. NCCI also responded to Florida’s notable Fee Schedule changes through its loss cost analysis, an example of what Glenn described as the bureau’s responsibility, as stewards of a healthy system, to share trends and incorporate them into loss cost actions as appropriate.
Glenn’s broader point was that the cross-state variation is not random. Economic, medical, infrastructure, and workforce trends interact differently in different jurisdictions, and the bureau filings that result reflect those underlying differences. A 2026 loss cost change that ranges from -15.6% to +22% is not noise. It is a map of where labor markets, medical cost structures, fee schedules, and regulatory environments are diverging.
For multi-state carriers, the lesson is that the national headline does not describe any individual state accurately. State-level filings, fee schedule changes, and bureau decisions can move material amounts of premium and reserve adequacy without ever showing up in the national average. Planning at the national level is necessary. It is not sufficient.
The Collaboration Layer Most Carriers Don’t See
One of the more revealing themes of the panel was how openly the three CEOs talked about working together. The bureaus are competitors in some technical sense, but the way they described their relationship was anything but adversarial.
Tracy Ryan put it this way. “We may operate in different jurisdictions, but we stay closely connected through the data we collect, the trends we watch, and the stakeholders we serve. I have found tremendous value out of the collaboration we have.“
Coleman echoed the point, emphasizing that the strongest work on emerging trends comes through partnership and collaboration across the bureaus and NCCI.
That collaboration is not symbolic. It is operational. The data exchanges, methodology comparisons, and trend identification work that happens between NCCI, the WCIRB, and the NYCIRB produce a level of cross-jurisdictional understanding that no single carrier could build on its own. For carriers and administrators paying attention, the implication is clear. The bureaus are making the system more comparable across states, even as the rules themselves remain different. That comparability is a tool, if your own operation is set up to use it.
Compliance Reporting Is Where the Operational Complexity Lives
The conversation at AIS 2026 stayed at the strategic level, but the operational reality for multi-state carriers is that the divergence between NCCI, the WCIRB, and the NYCIRB shows up most concretely in compliance reporting. This is the part of the job that does not make the headline slides, but it is where the multi-state complexity becomes a daily workload.
Each bureau has its own reporting requirements, classification systems, statistical plans, and timing. NCCI states require POC, WCPOLS, and WCSTAT reporting on the bureau’s cadence. California operates under WCIRB’s statistical reporting structure. New York requires NYCIRB compliance, including the indemnity and medical data calls Attie called out as part of the bureau’s modernization push. The transition to three-decimal-place loss cost values in New York in late 2025 is a small example of the kind of technical change that creates real operational work for carriers trying to keep policy administration accurate across jurisdictions.
For Chief Underwriting Officers and operations leaders, the compounding effect of this complexity over time is significant. Every regulatory change in every jurisdiction creates engineering work, training requirements, and audit trails. The carriers who handle this well tend to share one trait. Their platforms were designed for multi-jurisdictional complexity from the start, not patched together after the fact.
What a Multi-State Operator Should Actually Do With This
Three operational implications stand out for any carrier or administrator running across NCCI states, California, and New York.
First, build state-level pricing intelligence that respects independent-bureau cycles. The WCIRB and NYCIRB file on their own cadences and respond to their state-specific data faster than the annual NCCI loss cost cycle. Carriers writing in California and New York need the analytical capability to read those filings in real time and adjust pricing accordingly. Treating California and New York as variants of the national average is a recipe for being wrong-footed by the next filing.
Then, design claims strategies that flex by jurisdiction. Cumulative trauma in California, broad coverage in New York, and fee schedule structures across NCCI states all create different claim trajectories. A claims program optimized for an NCCI-state book may be inadequate for California. A return-to-work program designed for a high-physical-demand book may not translate to New York’s professional services concentration. Multi-state claims operations need the data segmentation to manage each state on its own terms.
Lastly, treat regulatory and bureau awareness as a competitive advantage. The Nevada and Florida actions Glenn described are examples of the kind of changes that can move material amounts of premium and reserve adequacy in a single filing cycle. Carriers and administrators who track those changes early can adjust strategy. Those who do not get surprised by renewal and audit cycles. Modern policy administration platforms like TruePolicy™ are built specifically to support the multi-state complexity that comes with operating across NCCI states, California, and New York simultaneously, including the bureau-specific compliance reporting (POC, WCPOLS, WCSTAT) that each jurisdiction requires.
Why This Matters
The three CEOs on stage disagreed on almost nothing and ran their states almost nothing alike. That paradox is the entire job for anyone with exposure across all three. The challenge is not understanding any single state in isolation. The challenge is having the operational and analytical capability to manage all three at once, with the right level of state-specific intelligence flowing into pricing, claims, and reserving decisions.
The 2025 results made the case for why this matters more in 2026 than it did in 2023. With premium trajectories diverging materially between the three blocks, with cumulative trauma redrawing California’s claim composition, with New York’s structural environment evolving around automation, remote work, and AI, and with NCCI states themselves showing wide variation in 2026 loss cost actions, the carriers and administrators who built multi-state operational capability will be the ones managing the differences instead of being managed by them.
Let’s Talk
If you are navigating multi-state complexity, evaluating how your platform supports California, New York, and NCCI states simultaneously, or thinking about how to translate the three-bureau dynamic into operational strategy, I would welcome the conversation. Book a discovery call with me.
Additional Resources from NCCI
For readers who want to go directly to the NCCI source materials referenced in this post:
