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.
Reasonable Compatibility Straw Models: Federal Requirements and State Options for Constructing a State’s Financial Reasonable Compatibility Standard
Manatt Health Solutions – Deborah Bachrach and Kinda Serafi
Manatt Health Solutions has created Reasonable Compatibility Straw Models to help state implementers better understand how to operationalize the Affordable Care Act’s (ACA) eligibility rules in their state systems. These models walk through reasonable compatibility income eligibility determination process flows for Medicaid, CHIP and advance premium tax credit / cost sharing reduction (APTC/CSR) when self-attested income data does not match data from automated sources. The following slide deck was developed in collaboration with the State Network and NASHP’s Maximizing Enrollment program and contains:
• An overview of reasonable compatibility requirements and how they fit into the new streamlined eligibility framework required under the ACA;
• Straw models for Medicaid, CHIP, and APTC/CSR requirements to help states construct verification processes consistent with the reasonable compatibility standards; and,
• Illustrative examples of how the reasonable compatibility standards might work in practice for individuals at various income levels.
Additional information on reasonable compatibility is available in an archived version of the July 16th, 2012 webinar hosted by the State Health Reform Assistance Network and Maximizing Enrollment. During the webinar the authors of this resource walked through the straw models and state and federal officials provided additional insights on the reasonable compatibility standards.