The Centers for Medicare and Medicaid Services (CMS) finalized its annual Notice of Benefit and Payment Parameters for 2018
(NBPP) and its 2018 Letter to Issuers in the Federally-Facilitated Marketplaces
(Letter) on December 16, 2016. As is typical, the NBPP addresses a breadth of issues relative to health plan regulation as well as Marketplace operations. The Letter provides operational and technical guidance for issuers seeking to offer Qualified Health Plans (QHPs) and Standalone Dental Plans (SADPs) on Federally-Facilitated Marketplaces (FFMs) and State-Based Marketplaces on the Federal Platform (SBM-FPs).
Key changes CMS made when finalizing the documents include:
- adjusting the certification and rate review timelines;
- making changes to risk adjustment calculation; and
- declining to institute proposed changes to network adequacy and discriminatory plan review.
CMS also instituted policy changes on which input was sought in the proposed NBPP and draft Letter, including:
- related to guaranteed issue and small group coverage;
- devoting 3% of FFM user fees to education and outreach;
- continuing to pro-rate the SBM-FP user fee (to 2% for 2018); and
- eliminating the FF-SHOP participation requirement for small group carriers that participate in the individual market FFM.
CMS also announced: which standardized plan options apply to each FFM and SBM-FP state; a March 1st deadline for SBM-FP states to notify CMS if they plan to participate in the differential display of CMS standardized options; and, other clarifications to the standardized options.
These and additional provisions revised from the proposed NBPP and draft Letter are highlighted in a summary
of the final NBPP and Letter drafted by subject matter experts from PCG’s Health team. The summary focuses on policy changes related to health plan regulation and certification and Marketplace establishment.
Regulators across the country are reviewing these provisions to understand the changes and how they will impact their regulation of health plans and the markets in their states. To support states as they analyze the impact of the final regulations and guidance for 2018, PCG also held a webinar on the final NBPP and Letter on Tuesday, January 10, and the slides are available here
. Please contact us at firstname.lastname@example.org
if you would like a recording of the webinar.
In addition to this guidance, CMS has also issued the following guidance related to QHP certification and marketplace operations in recent weeks: