On November 25, 2020, the U.S. Departments of Health & Human Services (HHS) and Treasury released the proposed 2022 “Notice of Benefit & Payment Parameters” (NBPP), the annual rule governing core provisions of the Affordable Care Act (ACA), including the operation of the marketplaces, standards for insurers, and the risk adjustment program. This expert perspective focuses on several provisions that have implications for state oversight of insurance markets and the state-based marketplaces. Comments on the proposed rule are due by December 30, 2020.
Consumer Impact Analysis Presentation
Wakely Consulting Group – Julia Lerche
As the 2015 open enrollment period approaches, one of the most significant challenges faced by marketplaces stems from the complicated nature of premium subsidy calculations, which may lead to potentially large swings in consumers’ after-subsidy premiums and could have tax liability implications. While marketplaces are attempting to make the renewal process as smooth as possible for consumers by facilitating auto-renewals into QHPs and, in the case of the FFM, rolling over 2014 APTCs into 2015, this approach could potentially be detrimental to some consumers, depending on factors such as income changes, premium variation, or a change in the benchmark plan. This slide deck was presented by Julia Lerche of Wakely Consulting Group on a Medicaid affinity group conference call facilitated by the State Network on August 5, 2014, along with a white paper describing the issue, and provides several scenarios in order to explain the potential impact of rate changes on consumers. This information can be utilized to inform modifications to carrier notices and communication planning (messaging, targeted outreach, education) for consumers, navigators/assistors and the media.