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.
Federally-Facilitated Exchanges and the Continuum of State Options
Manatt Health Solutions – Deborah Bachrach and Patricia Boozang
The Affordable Care Act allows states to create their own state-based health insurance exchanges or to allow a federally facilitated exchange to operate in the state. Proposed rules from the Department of Health and Human Services (HHS) also allow a partnership model where the federal and state governments share in the execution of exchange functions. This brief, supported by the State Network and published by the National Academy for Social Insurance, explores the continuum of options for states from fully state-based to fully federally facilitated, evaluating the considerations and implications associated with each option to help states determine which model may work best for the unique needs of their residents. The authors conclude that regardless of the model chosen, success can only be achieved through intensive collaboration between individual states and HHS.