On November 20, 2015, the Center for Medicare and Medicaid Services (CMS) issued a notice of proposed rulemaking (NPRM) for its 2017 Benefit and Payment Parameters (BPP) rule. Every fall CMS publishes a BPP proposed rule, which is finalized every spring for the next year. The BPP includes benefit parameters for qualified health plans and payment parameters for the Affordable Care Act’s premium stabilization programs—hence its name—but it is also an omnibus rule that CMS uses to amend and update all of its rules governing the ACA marketplaces and health insurance markets generally.
Perhaps the most notable changes in the 2017 BBP NPRM are its proposals to create standardized benefit plan options in the federally facilitated marketplace (FFM) and to impose new network adequacy standards, some of which apply in the FFM and some to all insurers. As is usually the case with the BPP, this is a massive NPRM—381 pages. It is also highly technical, making in most instances adjustments to existing rules rather than setting out new rules. This very brief summary will be followed over the next couple of days by a more complete analysis.
Read Full Article »