A NAIFA comment letter to the Centers for Medicare & Medicaid Services (CMS) submitted comments suggesting changes to the CMS proposed rule titled ”2024 Notice of Benefits and Payment Parameters,” published in the Federal Register on December 21, 2022.
This proposed rule includes proposed payment parameters and provisions related to the HHS-operated risk adjustment and risk adjustment data validation programs, as well as proposed 2024 user fee rates for issuers offering qualified health plans (QHPs) through Federally-facilitated Exchanges (FFEs) and State-based Exchanges on the Federal platform (SBE-FPs).
The proposed rule also proposes requirements related to updating standardized plan options and reducing plan choice overload; re-enrollment hierarchy; essential community providers (ECPs) and network adequacy; failure to file and reconcile; special enrollment periods (SEPs); the annual household income verification; the deadline for QHP issuers to report enrollment and payment inaccuracies; requirements related to the State Exchange improper payment measurement program; and requirements for agents, brokers, and web-brokers assisting FFE and SBE-FP consumers.
In NAIFA’s letter, NAIFA recommends adjustments to provisions that could hinder the ability of agents and brokers to best serve their clients. NAIFA believes that changes to existing regulations should ensure agents and brokers are able to continue their vital role in ensuring that millions of Americans have access to important health insurance benefits. NAIFA professionals are deeply rooted in their communities and are best positioned to understand the needs of consumers.
After the comment closing period, CMS will consider submissions before finalizing its proposed rule. NAIFA continues to work closely with CMS to ensure that agents and brokers receive the best tools and operate in a climate that allows them to serve their clients.