CMS Releases the Final 2020 Exchange Guidance

The Centers for Medicare & Medicaid Services (CMS) released final annual Exchange guidance for 2020 on April 18, 2019, via the Final Notice of Benefit and Payment Parameters for 2020 (NBPP) and the 2020 Letter to Issuers in the Federally-facilitated Exchanges (Letter) as well as ancillary guidance. CMS’s stated goals for this year’s guidance are:

  • Maintaining a stable regulatory environment;
  • Reducing regulatory burdens and providing issuers and states with greater flexibility;
  • Enhancing the role of states;
  • Empowering consumers; and
  • Improving affordability.

Many of the large-scale policy changes proposed in the draft guidance were not finalized, with CMS frequently citing the timing constraints that prevented them from doing so for the upcoming year (but potentially foreshadowing policy directives for future years). The areas highlighted for future policy making included:

  • Efforts to increase consumer transparency;
  • Changes to the practice of Cost Sharing Reduction (CSR) silver loading;
  • Non-Hyde Abortion Services Mirror Plan Offering Requirements;
  • Risk Adjustment Data Sources and Methodologies;
  • Mid-Year Formulary Changes.

With 2020 QHP deadlines quickly approaching, regulators across the country will be reviewing the final NBPP and Letter to understand how its changes to QHP certification, health insurance regulation, and Exchange operations impact the regulation of health plans and markets in their states. To support states as they analyze the impact of the changes, we created a summary of notable policy changes, which specifically highlights in red the differences between CMS’s proposed and finalized guidance.


For a quick overview of  key policy considerations, we have prepared a presentation for our readers. As always, we welcome any questions you have about how these changes may affect your state at

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