by Leslie Small
On Jan. 31, CMS released the 2021 Notice of Benefit and Payment
Parameters (NBPP), which is the annual omnibus regulation that outlines the
rules of the game for Affordable Care Act (ACA) exchange plans. But that was
only after a trade group for safety-net health plans sent a strongly worded
letter warning the Trump administration that the clock is ticking for issuers
to finalize their 2021 premiums and benefit designs.
In its Jan. 27 letter, the Association for Community Affiliated
Plans (ACAP) complained to CMS that the proposed 2021 NBPP "appears to be
stalled at the Office of Management and Budget." (The OMB completed its
review of the regulation on Jan. 29.) Insurers need to submit qualified health
plan (QHP) applications starting in early May, ACAP pointed out. "Building
in a minimum 30-day comment period in addition to 30 days for the Department to
review, revise, and release the final [rule] would allow just one month for
issuers to operationalize and implement necessary updates," the group
wrote. "This timeframe will not allow issuers sufficient time to prepare
products and operations for Benefit Year 2021."
Fritz Busch, an actuary with Milliman Inc., tells AIS Health
that the final NBPP has come out in April during the past two years, but before
that arrived much earlier. The delay of the NBPP "presents operational
challenges for a lot of plans, because so many plans are right in the middle of
doing their pricing and other planning for the year," he adds.
As for the content of the draft NBPP, the most
attention-grabbing proposed changes to the rules surrounding subsidy
eligibility. CMS said it’s seeking public comment on "new automatic
re-enrollment processes for enrollees whose share of the premium after applying
premium subsidies is $0, in order to reduce the risk of incorrect expenditures
on subsidies that cannot be recovered through reconciliation." In
addition, "periodic data matching standards would be amended to help
ensure premium subsidies are not inappropriately paid to enrollees who are
determined to be deceased, or dually eligible for Medicare."
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