In our ongoing commitment to supporting state-based exchanges and ensuring effective healthcare markets, CITIZ3N Government Solutions has recently provided detailed comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Proposed Notice of Benefit and Payment Parameters for 2026. As part of the industry, and in collaboration with our parent company Softheon Inc., which connects over 100 top-tier carriers to every ACA marketplace, we feel it’s crucial to share our insights on these potential regulatory changes.
Questioning User Fee Increases
First, we express concern over the proposed increase in user fee rates to 2.5% for HealthCare.gov and 2.0% for State-Based Exchanges on the Federal Platform, should the American Rescue Plan-enhanced subsidies not be extended by March 2025. Such an increase could exacerbate market uncertainties amid political and administrative shifts. Instead, we suggest that CMS explore policy alternatives to reduce costs for all stakeholders involved.
Supporting Silver Loading
Secondly, the CMS proposal to officially codify silver loading is a positive step. Originating as a state response to halted cost-sharing reduction payments in 2017, silver loading has successfully increased the value of premium tax credit subsidies, enabling more consumers to afford necessary healthcare. By formalizing this practice, CMS would offer much-needed predictability and stability to both insurers and consumers, especially during this transitional period of administration changes and legislative changes.
Enhancing Agent and Broker Oversight
CMS’ proposal to expand oversight for agents and brokers, particularly focusing on lead agents, reflects a move towards more robust regulation, codifying practices already in place. This change is intended to reinforce marketplace integrity and reduce instances of fraud and abuse. However, it’s crucial that CMS provides clear guidelines on what constitutes a risk to program integrity and engages with stakeholders, including states and exchanges, to ensure these measures are both effective and equitable.
Improving Tax Filer Compliance
The proposal to extend notifications to tax filers who have not reconciled their Advance Premium Tax Credits (APTC) for two consecutive years is another commendable step. This will likely enhance compliance and understanding of tax obligations among consumers, offering them a chance to rectify their tax situations before subsidy termination.
Final Thoughts
As we navigate these proposed changes, it’s vital for CMS to consider their impacts comprehensively, ensuring that Qualified Health Plans can be offered in a manner that balances affordability, access, and efficiency. We stand ready to engage further with CMS to refine these proposals, aiming for a regulatory environment that supports the health needs of all Americans.
For more details or to discuss these issues further, feel free to reach out to Robert Miller, Genergal Manager, at rmiller@citiz3n.com.
