Pennie Responds to CMS Proposed Payment Notice

The U.S. Department of Health and Human Services, Centers for Medicare & Medicaid Services (CMS) Notice of Benefit and Payment Parameters (NBPP) for PY2025 proposed rule was issued in Nov 2023 for comment on proposed standards for issuers and marketplaces as well as requirements for agents, brokers, web-brokers, enrollment entities and assisters to help marketplace consumers. Pennie provided comments prior to the deadline on Jan 8. The proposed rules once finalized will take effect in 2025. The NBPP:

• Proposes new federal standards for certain marketplace operational procedures and would require state-based marketplaces (SBMs) to implement new network adequacy requirements
• Provides additional flexibilities for state implementation of Essential Health Benefit (EHB) standards
• Would remove certain administrative barriers that prevent individuals from gaining and maintaining coverage, while extending enrollment opportunities during the plan year
• Provides guidance for states on the federally-facilitated marketplace (FFM) and state-based marketplaces on the federal platform (SBM-FP) regarding the implementation of standardized and non-standardized plans and asks whether it should require state-based marketplaces (SBM) to implement standardized plans
• Would require state agencies, including marketplaces, to pay to use an optional federal income verification data check that Pennie currently uses

Pennie responded with support for:

• CMS providing State-based marketplaces (SBMs) the necessary flexibility to determine how to implement standardized options as states are in the best position to determine what will best meet the needs of their individual markets.
• The proposal to allow the inclusion of routine adult dental services as an Essential Health Benefit
• The proposal clarifying that issuers have the flexibility to extend monthly premium payment deadlines when they experience billing or enrollment problems due to high volume or technical errors or are directed to do so by applicable state or federal authorities.
• The proposal to allow all exchanges to accept an applicant’s attestation of incarceration status without having to electronically verify that a consumer is not incarcerated
• The proposal to make the Special Enrollment Period (SEP) for individuals with household income at, or below, 150 percent of the federal poverty level (FPL) permanent
• Keeping federal regulations agnostic as to which state entity establishes and enforces network adequacy standards, provided such standards meet or exceed any federal minimum standard

Pennie opposes CMS’s proposal to require SBMs that utilize the optional Verify Current Income (VCI), or Equifax, check within the Federal Data Services Hub (FDSH) to now pay for the service. Pennie currently utilizes this service as a secondary income verification source when the Internal Revenue Service (IRS) returns applicant income data that is inconsistent with the income attested on a Pennie application.

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