Ryan Smith is the Senior Solutions Advisor for True Insurtech Solutions
Workers’ compensation is a national industry with no national system. Every state sets its own rules, its own benefit structures, its own rate-setting processes, and its own regulatory priorities. And every state produces its own loss experience shaped by a unique combination of workforce composition, industry mix, medical cost dynamics, and legislative history.
That reality is why the closing session of AIS 2026 may be one of the most strategically valuable conversations on the entire agenda. NCCI President and CEO Tracy Ryan will be joined by Andrea Coleman, President and CEO of the WCIRB (California’s rating bureau), and Jeremy Attie, President and CEO of the NYCIRB (New York’s rating bureau), for a session called “Every State Has a Story: CA, NY, and NCCI.”
This isn’t a regulatory update panel. It’s a conversation between the three organizations that, collectively, provide the data infrastructure and rate recommendations for most of the U.S. workers’ compensation market. When these three leaders sit down together, the perspective they bring spans nearly the entire landscape.
Why CA, NY, and NCCI Matter Together
NCCI provides ratemaking services in 38 states. California and New York operate independently through the WCIRB and NYCIRB respectively. Together, these three organizations cover the overwhelming majority of U.S. workers’ compensation premium volume.
But the significance of this panel goes beyond market coverage. California and New York are the two largest independent-bureau states, and their dynamics often diverge from the NCCI-state average in meaningful ways. California alone accounts for roughly 24% of the national workers’ compensation marketplace. New York is the next largest independent state. What happens in these two markets shapes industry-wide results, and the factors driving their performance don’t always track with the countrywide trends NCCI reports at the national level.
The independent bureaus also tend to update their loss cost projections more frequently than NCCI’s annual cycle. The WCIRB and NYCIRB typically file on a semi-annual or annual basis and can react to emerging trends faster as a result. That responsiveness means that California and New York are often early indicators of where the broader market may be heading.
For carriers and administrators operating across multiple states, the interaction between NCCI-state dynamics and the independent-bureau states creates a strategic complexity that topline national data can’t capture. This session is designed to surface that complexity.
California: Rate Pressure Reversing
California’s workers’ compensation market has been one of the most closely watched in the country, and recent developments signal a potential inflection point.
After years of rate decreases that mirrored the national trend, the WCIRB made headlines in 2025 when it requested an 11.2% increase in pure premium rates. The California Insurance Commissioner ultimately approved a smaller 8.7% increase effective September 1, 2025. Either way, it was a significant single-year increase in a market that had been trending downward, and the filing itself signaled that California’s loss experience was diverging from the broader favorable trend.
Andrea Coleman took over as President and CEO of the WCIRB in 2025, bringing over 20 years of insurance leadership experience including roles at global insurers focused on underwriting and complex operations. Her tenure has coincided with a period of transition for the California market, and the WCIRB has already submitted its September 2026 Regulatory Filing with proposed classification and rating plan changes.
The dynamics driving California’s experience are state-specific but instructive. California’s medical cost structure, benefit levels, attorney involvement patterns, and industry mix all create a claims environment that functions differently from most NCCI states. When the national story is “combined ratios below 90 for eight consecutive years,” the California story may be more nuanced. Understanding where and why California diverges is essential for anyone with exposure in the state.
New York: Large Decreases, Unique Structures
New York presents a different picture. The NYCIRB’s most recent loss cost filing proposed an average decrease of 13.2%, effective for policies renewing on or after October 1, 2025. That’s a substantial reduction, and it reflects favorable loss experience in the state.
But New York’s system has structural characteristics that make direct comparisons to NCCI states complicated. The state’s benefit levels are among the highest in the country, with maximum weekly compensation rates that significantly exceed those in most other states. New York’s coverage requirements are broader than most states, with only narrow exemptions for closely-held corporations and sole proprietors with no employees. The state adds a standard-premium assessment to fund special obligations. And the New York State Insurance Fund operates as a major market presence in ways that don’t have direct parallels in most other states.
Jeremy Attie leads the NYCIRB, which has been actively modernizing its data infrastructure, including expanding participation in indemnity and medical data calls and transitioning to three-decimal-place loss cost values as of October 2025. These may sound like technical changes, but they reflect a broader effort to increase the precision and granularity of the data available to carriers operating in New York.
For multi-state operators, New York’s large rate decreases can create a misleading impression of ease. The underlying system is complex, benefit levels are high, and the regulatory environment requires constant attention.
NCCI States: Favorable but Not Uniform
The NCCI-state picture, as covered earlier in this series, shows strong aggregate performance: an 86% combined ratio, declining frequency, and significant reserve redundancy. But within those 38 states, the variation is meaningful.
NCCI’s 2025 State of the Line data showed that 31 states experienced decreases in direct written premium. Rate and loss cost decreases averaged about 6% from 2024 to 2025 based on approved NCCI filings. But some states saw larger decreases, some smaller, and a few (like Nevada) actually saw increases. The drivers behind those differences include state-specific claims experience, workforce composition, industry mix, medical cost patterns, and regulatory decisions.
Donna Glenn’s Wednesday morning session at AIS 2026 on “Connecting Themes That Impact Results Across States” will bring together economic, medical, infrastructure, and workforce trends to illuminate how these factors shape state-level performance. That session sets the stage for the CA/NY/NCCI panel by establishing the framework for understanding why states diverge.
The combination of Glenn’s analytical session and the three-bureau panel creates a two-part arc: first the data-driven explanation of cross-state variation, then the practitioner-level conversation about how the three major rating organizations are navigating those differences.
What Multi-State Operators Should Be Thinking About
If you’re managing workers’ compensation across multiple states, and particularly if your footprint includes California, New York, and NCCI states, the state-level story isn’t just context. It’s operational strategy.
Pricing intelligence needs to be state-specific. A national view of rate adequacy doesn’t tell you whether your California book is mispriced relative to the WCIRB’s emerging loss cost direction, or whether your New York book is properly reflecting the state’s unique benefit structure. Multi-state operators need the analytical capability to evaluate rate adequacy on a state-by-state basis.
Claims management strategies can’t be one-size-fits-all. Medical cost dynamics, fee schedule structures, treatment patterns, and attorney involvement all vary by state. A claims strategy optimized for an NCCI state with a Medicare-based physician fee schedule may be inadequate for California, where the medical cost environment operates under different constraints.
Regulatory awareness is a competitive advantage. The independent bureaus in California and New York move at a different pace than NCCI’s annual cycle. Being aware of upcoming filings, proposed rate changes, and regulatory shifts before they take effect gives carriers time to adjust strategy.
Technology needs to support multi-jurisdictional complexity. Every state has different reporting requirements, classification systems, rating plans, and regulatory expectations. The operational burden of managing across jurisdictions is substantial, and it compounds as your footprint grows. The organizations that handle this well are the ones with platforms built for multi-state operations, not single-state systems patched together.
What I’ll Be Watching at AIS 2026
The CA/NY/NCCI panel is the kind of session where the value is in the conversation, not just the data. Here’s what I’ll be listening for:
Where do Coleman and Attie see their states diverging from the national trend? California’s rate increase request was a signal. I want to understand the loss experience driving it and whether it’s accelerating or moderating.
How are the three organizations thinking about medical cost challenges? The utilization vs. price dynamic plays out differently depending on a state’s fee schedule structure and regulatory approach. Getting the California and New York perspectives alongside NCCI’s national view will be instructive.
What shared challenges are the three bureaus navigating? Demographic shifts, economic uncertainty, medical inflation, and data modernization are cross-cutting themes. Understanding where the three organizations are aligned and where they’re taking different approaches reveals a lot about the strategic landscape.
What does Tracy Ryan signal about NCCI’s forward-looking priorities? Ryan opened AIS 2026 with her executive overview on Tuesday. This panel is her closing appearance. The themes she chooses to highlight in conversation with Coleman and Attie will signal where NCCI sees the most important cross-jurisdictional dynamics heading into 2027.
From Data to Action
So far in our AIS 2026 spotlight series, we’ve covered the financial benchmarks that define the line’s performance, the economic forces shaping the operating environment, the demographic shifts changing who gets hurt and how, and now the jurisdictional complexity that makes workers’ compensation one of the most operationally challenging lines in the P/C industry.
The connecting thread across all four is this: the data NCCI and the independent bureaus produce is extraordinarily valuable. But it’s only as useful as your organization’s ability to translate it into decisions. The carriers and administrators that outperform over time are the ones that combine industry intelligence with operational capability, turning macro trends into book-level strategy and national benchmarks into state-specific action.
That’s the work we help organizations do every day at True.
