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Hart Health Summary-2025 ACA Exchange Plan Notice of Benefit & Payment Parameter
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Hart Health Summary-2025 ACA Exchange Plan Notice of Benefit & Payment Parameter
On April 2nd, the U.S. Department of Health and Human Services (HHS) issued its 2025 Notice of Benefit and Payment Parameters (NBPP), which finalizes changes to plans established by the Affordable Care Act (ACA) (e.g., qualified health plans (QHPs)). The attached document compares select provisions from the proposed and final rules that may be of interest to you, most notably, those that relate to network adequacy, the provision of essential health benefits (EHBs), prescription drug benefits, and standardized plan options. Of special note, HHS also addressed a proposal from the Federal Independent Dispute Resolution (IDR) Operations rules related to health plan direct payment of Federal IDR Fees to the Federal government.
Key highlights:
- Network Adequacy: HHS finalized that State Exchanges
and State-Based Exchanges on the Federal platform (SBE-FPs) must establish
and impose quantitative time and distance network adequacy standards that
are at least as stringent as the Federally-Facilitated Exchange (FFE) time
and distance standards established for QHPs, but do not need to comply
with the appointment wait time standards. To give States time to comply,
HHS will require implementation for plan years beginning on or after
January 1, 2026 (vs. 2025). - Non-standard Plan Options: With modifications, HHS finalized
an exceptions process that would allow issuers to offer additional
non-standardized plan options (in excess of the limit of two) per product
network type, metal level, inclusion of dental and/or vision benefit
coverage, and service area for PY 2025 and subsequent plan years, if
issuers demonstrate that these additional non-standardized plans have
specific design features that would substantially benefit consumers with
chronic and high-cost conditions. - Factoring Unpaid Federal IDR Admin
Fees Into Federal Issuer Financial Calculations: For purposes of calculating
advance payments of the premium tax credit, advance payments of and
reconciliation of cost-sharing reductions, payment of
Federally-facilitated Exchange user fees, payment of State Exchanges
utilizing the Federal platform user fees, and risk adjustment,
reinsurance, and risk corridors payments and charges, HHS takes into
account debts that an issuer owes the Federal government. In this rule,
HHS finalized a provision that will allow the Department to take into
consideration unpaid Federal IDR admin fees owed by the issuer to the
Federal government as part of those calculations. However, this will not
become effective until the Federal IDR Operations rule is finalized (and
finalizes the proposal for health plans to directly submit payment of
Federal IDR fees to the federal government rather than to the IDREs).
- Network Adequacy: HHS finalized that State Exchanges
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