INSTITUTIONAL RISK INTELLIGENCE / REINSURER

Acadia Healthcare — Carrier/Reinsurer Intelligence View

Acadia’s disclosed PLGL development shows that claim frequency, prior-year severity and insurance terms can move enterprise earnings materially; IRI’s commercial value is to identify facility-level mechanisms early enough to test corrective conditions before they mature into reserve development.

Evidence through 2026-09-172024–2026Report IRI-ACADIA-CARRIER-20260917

DECISION BRIEF

The decision this evidence supports now.

Decision requiredAuthorize a facility-to-claim linkage review before the next underwriting and captive-governance cycle.
Recommended actionJoin facility recurrence findings to policy-year loss runs, claim taxonomy and corrective-action closure evidence.
Accountable ownerChief Risk Officer and captive board
Decision windowWithin 30 days
Escalation triggerEscalate when the same governed mechanism recurs across two facilities or appears in a maturing high-severity claim.
Economic rationaleThe public record shows a $52.7M unfavorable 2025 PLGL adjustment, a $181.8M year-end reserve and a further $28.6M Q2 2026 adjustment.

WHAT IRI MAKES VISIBLE

Intelligence not contained in any single source.

01

The 2025 PLGL reserve increased from $87.5M to $181.8M while estimated insurance recoverables increased from $9.3M to $28.8M.

02

Acadia recorded a $52.7M unfavorable 2025 adjustment tied to prior-year settlement costs, increased claim frequency and less favorable insurance terms.

03

After August 31, 2025 the captive disclosed $15M per claim and $25M for certain batched claims, with unnamed third-party reinsurance at $75M aggregate subject to exclusions.

04

Historical litigation verifies TDC reinsured a $15M excess $60M layer and Marsh USA acted as Acadia’s reinsurance broker for the 2017 placement; this is not represented as current.

05

A further $28.6M PLGL reserve adjustment was disclosed in Q2 2026.

DECISION IMPLICATIONS

Link facility mechanisms prospectively to claim frequency/severity.

Use findings as testable hypotheses for underwriting, captive governance and reinsurance.

Do not infer current external carrier identities.

Track corrective controls against recurrence and claims.

CONVERGENCE

Evidence → mechanism → consequence.

observedhigh confidence

PLGL development is an earnings-level variable.

The reserve nearly doubled year over year and the 2025 adjustment was attributed to settlement costs, increased frequency and less favorable insurance terms.

Why it matters. Reducing uncertainty around recurrence mechanisms can matter when reserve estimates are sensitive to frequency and severity.

CRF · insufficient evidenceCMDS · insufficient evidenceCOVE/F · appliedCOMPASS · not applicable
Framework analysis and evidence requirements

CRF

Enterprise PLGL development establishes financial context but does not identify which continuity stage, if any, generated the claims.

CMDS

Reserve and frequency disclosures do not establish a CMDS mechanism or stage.

COVE/F

The financial finding can be converted into an evidence requirement and accountable recurrence-control test without attributing a violence or extraction code.

Harm · observed PLGL reserve development and earnings adjustments are observed enterprise consequences.

Reinforcement Loops · hypothesis Repeated facility mechanisms may contribute to claim frequency or severity, subject to prospective linkage.

Verify: Finding prevalence versus later claims by facility and policy year · 90-day pilot, then quarterly

COMPASS

The enterprise PLGL finding contains no person-level longitudinal differential assessment.

Evidence still required: Facility-level event chronology; Claim-to-facility linkage; Stage-specific corrective-action evidence; Institution-specific policy, reporting, authority and corrective-action evidence; Facility-level recurrence data; Corrective-action closure evidence

Test this finding

Validate: Reconcile later filings and claims data.

Falsify: Later development is unrelated to detectable facility mechanisms.

Evidence: A-10K, A-Q2, A-PLGL

derivedhigh confidence

Risk transfer does not eliminate enterprise exposure.

At year-end 2025 Acadia disclosed $181.8M of PLGL reserves and $28.8M of estimated insurance recoverables.

Why it matters. The same mechanism can affect captive retention, reinsurance, earnings and capital differently.

CRF · not applicableCMDS · not applicableCOVE/F · appliedCOMPASS · not applicable
Framework analysis and evidence requirements

CRF

This finding concerns risk financing allocation rather than a clinical continuity stage.

CMDS

Risk-transfer structure alone does not establish a CMDS mechanism or stage.

COVE/F

The finding needs ownership and verification across captive, reinsurance and enterprise consequences.

Structural Drivers · observed Captive retention and external reinsurance govern how covered losses propagate.

Actors · observed Acadia and its captive are identified; the current external reinsurer remains unnamed.

Harm · observed Enterprise reserves materially exceed estimated recoverables at the evidence cutoff.

Verify: Share of modeled loss paths reconciled to current coverage · Before the next underwriting cycle

COMPASS

The risk-financing finding contains no person-level longitudinal assessment.

Evidence still required: Current coverage schedules; Policy-specific exclusions and attachment points

Test this finding

Validate: Obtain policy-year loss runs and coverage schedules.

Falsify: Policy evidence materially changes the public allocation.

Evidence: A-10K

observedhigh confidence

Historical tower architecture is verified; current external identities are not.

TDC is verified historically for a $15M excess $60M layer and Marsh for the 2017 placement; current SEC disclosure names only an unnamed third-party reinsurer.

Why it matters. Propagation can be shown without fabricating a current carrier.

CRF · not applicableCMDS · not applicableCOVE/F · appliedCOMPASS · not applicable
Framework analysis and evidence requirements

CRF

Historical tower identity is a provenance and temporal-validity finding.

CMDS

Broker and reinsurer identity does not establish a CMDS mechanism or stage.

COVE/F

The finding requires a verification gate that prevents historical counterparties from being represented as current.

Actors · conflicting Historical external actors are verified while current external identities remain unavailable.

Verify: Temporal identity validation for every named external counterparty · Before outreach or external attribution

COMPASS

Counterparty provenance has no COMPASS person-level assessment use.

Evidence still required: Current policy or authoritative counterparty confirmation

Test this finding

Validate: Obtain current policy or direct confirmation.

Falsify: A current authoritative source establishes the historical placement remains current.

Evidence: A-TDC-GA, A-TDC-NY-SEAL, A-10K

ECONOMIC EXPOSURE

Known money and modeled exposure are separated.

Booked / actual

$52,700,0002025 unfavorable PLGL reserve adjustment2025 Form 10-K
$28,600,000Q2 2026 PLGL reserve adjustmentQ2 2026 results
$49,000,0002025 EBITDA guidance reduction attributed to incremental PLGL expenseDecember 2025 PLGL update

Disclosed reserve

$181,800,000PLGL reserve at Dec. 31, 20252025 Form 10-K
$28,800,000Estimated insurance recoverable at Dec. 31, 20252025 Form 10-K

Modeled exposure

No governed value available.

Counterfactual value

No governed value available.

PROPAGATION

Where the exposure travels next.

Facility / patient

Facility recurrence

Repeated mechanisms generate incidents and complaints.

Acadia / captive

Claim frequency / severity

Maturing events increase defense, settlement and reserves.

Acadia Assurance Company

Captive layer

Professional-liability risk is financed through the captive up to disclosed limits.

Current third-party reinsurer — identity unverified

Reinsurance recovery

Covered losses can propagate subject to terms and exclusions.

Acadia / capital stakeholders

Earnings / capital

Reserve adjustments affect operating results.

STAKEHOLDER LEVERAGE

Exposure becomes actionable when the consequence chain is visible.

Select a stakeholder to trace exposure → newly visible intelligence → available action → downstream systemic effect. Every relationship remains bound to evidence state and explicit unknowns.

SELECTED STAKEHOLDER

Facility operations

Exposure carried
Operational recurrence, patient-safety events, complaints and control failures.
IRI makes visible
Governed recurrence and convergence patterns across facility evidence rather than isolated incidents.
Available action
Test recurrent mechanisms, attach corrective conditions and document closure evidence.
Downstream systemic effect
Fewer repeated mechanisms can reduce the upstream event stream that later matures into claims and enterprise exposure.
Evidence: A-10KClass: hypothesis
Evidence boundary

Facility-specific causation and StoneCrest-specific PLGL dollars are not established by enterprise disclosures.

INTERVENTION / VERIFICATION

Change the mechanism, then prove it changed.

01
immediateEnterprise risk and captive underwriting90-day pilot, then quarterly

Bind facility findings to policy-year loss runs and claim taxonomy.

Test whether governed recurrence findings lead claim frequency or severity.

Decision: Authorize the data join and define the pilot facility set.

Implementation: One governed policy-year data join using existing loss-run, RMIS and corrective-action records.

Economic effect: Tests an upstream control against publicly disclosed reserve and earnings volatility.

Target: Disconnect between facility evidence and actuarial development · Verify: Finding prevalence versus later claims by facility and policy year
02
near termFacility operations with enterprise risk oversightMonthly review for 12 months

Attach corrective conditions to recurrent mechanisms and monitor closure.

Create an auditable risk-control loop.

Decision: Approve required closure evidence and escalation thresholds.

Implementation: Add evidence requirements to the existing corrective-action workflow.

Economic effect: Reduces uncertainty about whether funded remediation changes recurrence before renewal.

Target: Repeated process failure · Verify: Recurrence and claim trend after verified closure

UNCERTAINTY

What would change the conclusion.

Unknowns

Current third-party reinsurer identity.

Current broker of record.

Current policy-specific attachment points/exclusions beyond aggregate disclosure.

No public filing attributes enterprise reserve development specifically to StoneCrest.

Sensitivities

Reserves/recoverables change as claims develop.

Predictive value requires prospective validation.

Limits

Do not represent enterprise PLGL as StoneCrest-specific.

Do not represent historical TDC/Marsh as current.

METHOD / PROVENANCE

Evidence → CRF → CMDS → COVE/F → MAM + PHC → Action → Monitor/Verify

Enterprise disclosures establish context, not facility causation.

Observed money remains separate from modeled exposure.

Unknown external identities remain unknown.

IDSourceScopeClass
A-10KAcadia Healthcare 2025 Form 10-KPLGL insurance, reserves and reinsuranceobserved
A-Q2Acadia Healthcare Q2 2026 resultsQ2 2026 PLGL adjustmentobserved
A-PLGLAcadia PLGL actuarial updatePLGL expense and guidanceobserved
A-TDC-GATDC National Assurance Company v. Marsh USA, LLCHistorical TDC layer and Marsh broker roleobserved
A-TDC-NY-SEALTDC National Assurance Company v. Marsh USA LLC — sealing ordersSealing boundaryobserved

EXHAUSTIVE INSURANCE / REINSURANCE EVIDENCE PASS

What the deeper public-record search adds.

01

Acadia reported a 168% increase in PLGL claim frequency in policy year 2025 versus 2024; elevated IBNR; projected 2025 PLGL expense of approximately $116M versus $54M in 2024; and assumed 2026 claim counts would remain roughly at the 2025 level.

Acadia December 2 2025 SEC-filed PLGL actuarial update
02

Acadia reported less favorable reinsurance terms versus prior years and a year-end 2025 net PLGL liability expectation of $145M-$165M at the December 2025 update.

Acadia December 2 2025 SEC-filed PLGL actuarial update
03

2025 Form 10-K disclosed $181.8M PLGL reserve, $28.8M estimated insurance recoverable and a $52.7M unfavorable PLGL adjustment.

Acadia 2025 Form 10-K
04

Successive public filings show captive limits increasing from $5M per claim through Aug. 2023, to $7M thereafter, to $10M after Aug. 2024, and to $15M per claim after Aug. 2025. Reinsurance limits also changed across those periods.

Acadia 2023, 2024 and 2025 Forms 10-K
05

After Aug. 31 2025 Acadia disclosed $15M per-claim captive coverage, $25M for certain batched claims, and $75M aggregate third-party reinsurance subject to exclusions; the external reinsurer is unnamed.

Acadia 2025 Form 10-K
06

In Sandoval, the applicable excess insurance policy was exhausted entirely by prior losses, leaving loss above primary coverage uninsured; $13.8M of the $15M settlement exceeded available primary coverage and was recorded as legal settlement expense.

Acadia Q2 2026 Form 10-Q
07

Historical litigation states TDC reinsured the $15M excess $60M layer of an Acadia Assurance excess policy and Marsh USA acted as Acadia reinsurance broker in the 2017 placement.

TDC National Assurance Company v. Marsh USA LLC, N.D. Georgia, June 30 2026
08

Acadia obtained sealing/redaction of substantial arbitration-related material in the TDC/Marsh proceeding.

TDC National Assurance Company v. Marsh USA LLC, S.D.N.Y. sealing orders
09

Acadia Assurance Company is listed by Tennessee as a pure captive licensed August 3 2016.

Tennessee captive statistics
10

The 2024 $19.85M federal/state settlement resolved allegations involving medically unnecessary inpatient services, excessive lengths of stay, staffing/training/supervision deficiencies, assaults, elopements, suicides, active-treatment deficiencies, assessment/treatment-plan deficiencies and discharge-planning deficiencies. DOJ states the claims were allegations only and there was no determination of liability.

U.S. Department of Justice, September 26 2024

RISK-FINANCING EVOLUTION

Retained/captive limits increased across successive policy structures.

PeriodCaptiveThird-party reinsurance
through Aug. 31 2023$5M per claim; $10M certain other claims$75M or $70M aggregate for certain other claims
after Aug. 31 2023$7M per claim; $10M certain other claims$78M or $75M aggregate for certain other claims
after Aug. 31 2024$10M per claim; $15M certain other claims; $25M certain batched claims$80M or $75M aggregate for certain other claims
after Aug. 31 2025$15M per claim; $25M certain batched claims$75M aggregate, subject to exclusions

IRI CONSEQUENCE CHAIN

Mechanism → claim → reserve → tower → uninsured tail → earnings.

01

Frequency shock → elevated IBNR → reserve development → PLGL expense/earnings impact.

02

Facility recurrence → claim frequency/severity → captive retention → reinsurance/aggregate erosion → possible exhaustion → uninsured tail.

03

IRI should measure remaining aggregate/layer capacity when policy data are available rather than assuming reinsurance remains fully available.

04

External enforcement mechanism classes should be crosswalked through CRF → CMDS → COVE/F → PHC/MAM and independently validated before attribution.

05

Increasing captive limits and less favorable reinsurance terms are contemporaneous observed facts; public evidence does not prove one caused the other.

EVIDENCE BOUNDARY

Still unknown after the exhaustive public-record pass.

Current external reinsurer identity — UNKNOWN.

Current broker of record — UNKNOWN; Marsh is historical only.

Current detailed attachment schedule and exclusions beyond aggregate public disclosure — UNKNOWN.

Prior losses that exhausted the Sandoval excess policy — not identified publicly.

StoneCrest-specific share of enterprise PLGL reserve — not established publicly.

Verified internal routes

Dulce Mooney
LinkedIn search verifies Acadia Assurance Company affiliation.

Tracy Raby, CPHRM
LinkedIn search verifies Acadia Healthcare affiliation; public organizational sources identify Corporate Director Risk.

Chase Fisher
LinkedIn search verifies Acadia Healthcare affiliation; public organizational sources identify Vice President, Litigation.

Rule

Historical participants are never promoted to current status without current authoritative evidence.