Hello Readers!
As we previewed in the January special edition of Health Policy News, more guidance on the 2026 final Notice of Benefit and Payment Parameters (NBPP) and Letter to Issuers in the Federally- Facilitated Marketplace (FFM) are included in this month’s edition. Our focus continues to be on the policy changes from year to year that are most pressing for regulators as they seek to provide guidance to Qualified Health Plan issuers in their states prior to the submission of forms and rates this spring.
Additionally, our subject matter experts delve into the use of SSA §1915(l) – STATE PLAN AUTHORITY as an option to tackle substance use disorder. As states continue to address access to and quality of SUD treatment, this flexibility could be a valuable tool for state policy makers.
Annual Exchange Guidance for 2026
The Centers for Medicare and Medicaid Services (CMS) finalized guidance for Exchanges and Qualified Health Plans (QHPs) for plan year 2026 prior to the end of the last administration, opening the door for states and insurers to move forward with the plan development and certification process. Our subject-matter experts have updated our overview of the most significant changes outlined in the proposed NBPP and the Letter that we released last November to reflect the final guidance and assist states as you prepare for the 2026 certification process. Please note that changes from the proposed guidance are noted in bold, to read the full summary please click here.
SSA §1915(l) – STATE PLAN AUTHORITY OPTION FOR SUD TREATMENT IN AN IMD
This article explores a relatively new authority vehicle, previewed for readers in looking back on 2024, and making predictions for 2025 December edition, the 1915(l) state plan option, that can be used to obtain SUD coverage in an IMD. Treatment in an Institution for Mental Disease (IMD) has long been barred by federal statute under what is commonly known as the IMD exclusion. However, changes in federal statute and further guidance from the Centers for Medicare & Medicaid Services (CMS) have opened the door for states to use IMDs in limited circumstances for individuals in need of SUD treatment. To read more about the ways CMS is innovating around 1915 (l) state plan options, click here.
Upcoming Webinar: Navigating the New Landscape: CMS Access & Quality Final Rule Webinar Part 3: Systems in Action
Join Public Consulting Group (PCG) Home and Community-Based Services (HCBS) subject matter experts for Part 3 of our webinar series on the CMS Access Final Rule (2442)! Get ready for an engaging session where we’ll focus on Systems in Action. Here’s what to expect:
Effective Evaluation: Explore strategies for system improvement through a collaborative approach. Engage in a guided self-reflection to evaluate ways your system can gain efficiency and impact.
Coordinated Processes: Learn how to leverage tools to help assess process gaps and challenges when multiple agencies or teams are involved.
Building Trust & Mutual Support: Explore strategies to strengthen collaboration by setting shared goals, clarifying roles, and maintaining transparency for long-term success.
Don’t miss this opportunity to engage in collaborative learning about critical incident management, grievance systems, and how successful partnerships are formed. Please see below for registration and event info.
DATE: March 11, 2025 TIME: 12:00 – 1:00PM EST
Register Here!