Regulatory Analysis | Apr 6, 2015

Final HHS Notice of Benefit and Payment Parameters for 2016: Brief Summary of Key Provisions for the 2016 Plan Year

Georgetown University Health Policy Institute – Center on Health Insurance Reforms

On February 27, 2015, the federal Department of Health and Human Services published the Notice of Benefit and Payment Parameters for 2016 Final Rule, which included several provisions pertaining to form review.  This analysis, prepared by the Georgetown University Health Policy Institute’s Center on Health Insurance Reforms, provides a brief summary of the key provisions specific to form review and other notable provisions specific to the 2016 plan year.  Included in the final rule are provisions on enrollment periods, definition of habilitative services, meaningful access to coverage materials, annual update to cost-sharing limits, pediatric age, and the drug exceptions process.


Expert Perspectives

February 3, 2023

New CMS Guidance on Unwinding Provisions in the CAA, 2023

On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.

February 1, 2023

CMS Approves First-in-Nation Justice-Involved Re-Entry Section 1115 Demonstration

On January 26, 2023, the Centers for Medicare & Medicaid Services approved California’s request to amend the California Advancing and Innovating Medi-Cal Section 1115 demonstration. This expert perspective describes the amendment, a centerpiece of which is approval for California Medicaid to provide a targeted set of Medicaid services to youth and adults in state prisons, county jails, and youth correctional facilities for up to 90 days prior to release. By providing re-entry services to Medicaid-enrolled individuals who are incarcerated, California aims to build a bridge to community-based care for justice-involved enrollees, offering them services to stabilize their physical and behavioral health conditions and establishing, prior to release, a re-entry plan for their community-based care.

January 27, 2023

Federal Ruling Provides Text Messaging Flexibility to Support State’s Unwinding Efforts

On January 23, 2023, the Federal Communications Commission issued an important ruling that provides states with new flexibility to support enrollee outreach and communication efforts as part of their processes to unwind the Medicaid continuous coverage requirement. The ruling permits state agencies and their partners to send text messages and make phone calls to individuals about enrollment-related issues not only for Medicaid but for other state-run health insurance programs, including marketplace coverage. This expert perspective reviews the ruling and implications for states.