On November 15, 2023, the Centers for Medicare & Medicaid Services released its proposed 2025 Notice of Benefit and Payment Parameters, the annual regulation which governs core provisions of the Affordable Care Act. This expert perspective focuses on aspects of the proposed rule likely to be of interest to state officials, including requirements for State-Based Marketplaces to align with the standards of the Federally Facilitated Marketplace, proposals for states to update essential health benefits, and initiatives to ease the eligibility and enrollment process for consumers.
Enforcement of the No Surprises Act: Considerations for States
State Health and Value Strategies hosted a webinar on Thursday, November 4 from 1:00 to 2:00 p.m. ET, during which experts from the Georgetown University Center on Health Insurance Reforms and GMMB provided an overview of federal regulators’ proposed approach to enforcement of the No Surprises Act (NSA) as well as share strategies to consider in planning provider and consumer education efforts. The webinar also included presentations from three states on their enforcement approaches to the NSA: Maryland, Pennsylvania and Texas, followed by a question and answer session. In case you missed it, a corresponding expert perspective is posted on our website along with other NSA-related materials on a resource page for states. We will continue to update this resource page with relevant state information.
The NSA takes effect on January 1, 2022, extending comprehensive protections from balance billing to those individuals not already covered by state-enacted protections, including the nearly 135 million people in self-insured plans. Federal regulators are relying on states to be the primary enforcers of the provisions that apply to insurers and providers and facilities, including air ambulances. Enforcement may therefore require state agencies other than departments of insurance to engage in enforcement efforts.