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.
- Manual for Reconciliation of the Cost-Sharing Reduction Component of Advanced Payments for Benefit Year 2016: https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/Final-Manual-for-Reconciliation-of-the-Cost-Sharing-Reduction-Component-of-Advance-Payments-for-the-2016-Benefit-Year.pdf
- Key Priorities for FFM Compliance Reviews for the 2017 Benefit Year: https://www.cms.gov/CCIIO/Resources/Forms-Reports-and-Other-Resources/Downloads/Compliance_Review_Table-KeyPriorities_2017Final.pdf
- FAQ on Agent/Broker Compensation and Discriminatory Marketing Practices: https://www.cms.gov/CCIIO/Resources/Fact-Sheets-and-FAQs/Downloads/Agent-Broker-Compensation-and-Discriminatory-Marketing-Practices.pdf
- Final 2018 Actuarial Value Calculator Methodology: https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/Final-2018-AVC-Methodology121616.pdf
- Key Dates for 2017: QHP Certification, Rate Review, Risk adjustment and Reinsurance: https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/Key-Dates-for-Calendar-Year-2017-12-16-16.pdf
- Bulletin: Timing of Submission and Posting of Rate Filing Justifications for the 2017 Filing Year for Single Risk Pool Coverage: https://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/RR-timeline-bulletin-final-12-16-16.pdf
- Final CMS ECP list for PY 2018: https://www.cms.gov/cciio/programs-and…/final-cms-ecp-list-py-2018_12-16-16.xlsx