Health Policy News September 2016

Today’s special edition of Health Policy News focuses on the Proposed Notice of Benefit and Payment Parameters (NBPP) for 2018 issued by the Centers for Medicare & Medicaid Services (CMS) on August 29th.

PCG subject matter experts are hosting a webinar about the proposed regulations tomorrow, Thursday, September 15th at 3:00pm EST. See below for information about how to join the webinar.

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Summary of Key Changes Related to Health Plan Regulation and Qualified Health Plan (QHP) Certification

CMS released its annual NBPP earlier than it has done in prior years in order to provide more market certainty. As is typical, the NBPP for 2018 addresses a breadth of issues relative to health plan regulation as well as Exchange operations. In releasing the proposed rule, HHS highlighted four goals:

  • Supporting insurers with high cost enrollees and updating risk adjustment
  • Strengthening the Marketplace risk pool
  • Improving enrollment growth
  • Removing obstacles to insurer entrance, growth and innovation

Regulators across the country are reviewing the proposals to understand the changes to QHP certification and health insurance regulation and how the changes would impact their regulation of health plans and the markets in their states. To support states as they analyze the impact of the proposed regulations for 2018, PCG subject matter experts have created a summary of notable changes relative to QHP certification and health insurance regulation, available here. Key changes outlined in this detailed summary include:

  • Annual updates to key financial limits and charges
  • Changes necessary to advance policy innovations from last year, including to the standardized plans, network adequacy disclosures and requirements for State-based Exchanges on the Federal Platform (SBE-FP)
  • Clarifications and changes to requirements for carriers and plans that will participate on Exchanges
  • New provisions to encourage more carrier participation in the Exchange
  • Changes to the risk adjustment program
  • Adjustments to the Medical Loss Ratio rules

Within this year’s NBPP, HHS is also seeking input on an unusually large number of issues being considered for future rule-making, including the following:

  • How to improve transitions to Medicare and coordination of benefits between QHPs and Medicare
  • How to use remaining funding to ensure those previously enrolled in the Pre-Existing Condition Insurance Program do not face gaps coverage now that they are enrolling in QHPs
  • Whether additional protections against “surprise bills” from out-of-network providers at in-network facilities are necessary
  • Whether the SBE-FP user fee should be continued to be phased in and how user fees should be allocated for outreach and education
  • Whether regulatory or policy changes are necessary for Exchanges to facilitate innovation in coverage

The NBPP for 2018 also addresses a number of Exchange operational issues related to eligibility, enrollment and consumer assistance. PCG will distribute a second summary focused on these provisions in the coming weeks.

Comments on the proposed NBPP for 2018 are due by October 6th at 5:00 pm.

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Upcoming Webinar

PCG subject matter experts are hosting a webinar on the NBPP for 2018 tomorrow, Thursday, September 15th at 3:00pm EST to highlight some of the more notable provisions. Those interested in attending Thursday’s webinar may do so online or by phone.

To attend the webinar online:

Go to the WebEx registration link here.

Connect to the audio using your computer.

To attend by phone:

Dial: 1-877-668-4493

Enter access code: 798 822 617

If you have any difficulty accessing the webinar or if you are unable to join and would like to be sent a recording of the presentation, email Bobby Riso at

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