Stakeholder Views on CMS’s 2024 Discover of Advantages and Fee Parameters: Client Advocates


By Kristen Ukeomah and Karen Davenport

In December, the Facilities for Medicare & Medicaid Providers (CMS) launched its proposed Discover of Advantages and Fee Parameters (NBPP) for plan yr 2024, an annual rule that governs the Inexpensive Care Act (ACA) medical health insurance Marketplaces and establishes requirements for well being insurers. The CHIR workforce has reviewed the feedback submitted by choose stakeholder teams in response to the proposed rule. For the primary weblog in our sequence, we checked out feedback submitted by well being insurers and consultant associations. On this second weblog, we summarize feedback from shopper advocacy organizations, together with:

Whereas these organizations supplied feedback on numerous points, this weblog focuses on 4 major subjects: community adequacy, door-to-door enrollment help, re-enrollment determination hierarchies, and standardized plans.

Community Adequacy

For plan yr 2024, CMS proposed requiring extra Market plans to make use of supplier networks that adjust to community adequacy and important group supplier (ECP) necessities, eliminating a earlier exemption for plans and not using a supplier community. As well as, the 2024 NBPP would modify the ECP requirements by creating two new ECP classes for Psychological Well being Services and Substance Use Dysfunction (SUD) Remedy Facilities. Furthermore, HHS proposes a requirement for insurers to exhibit compliance with the wait time requirements established in 2023.

The entire shopper teams in our pattern assist the supplier community requirement. NHeLP notes that non-network plans make it tough for federal regulators to make sure that plan enrollees have entry to care. As well as, the entire teams in our evaluate approve of the 2 new ECP classes. Group Catalyst emphasizes the significance of ECPs for communities of coloration and different underserved communities. AARP equally notes how the 2 new ECP classes will assist dismantle obstacles to high quality take care of older People. Households USA strongly helps these additions, additional advocating for requirements associated to behavioral well being companies to individually look at adequacy for adults and youngsters.

A few shopper teams additionally mentioned the appointment wait time requirements, usually supporting the coverage. ACS-CAN believes that quantitative requirements, like wait occasions, are important in figuring out the adequacy of a plan’s community. Households USA urges CMS to formalize steerage round wait occasions in laws, versus altering these measures yearly.

Door-to-Door Help

CMS additionally proposed rescinding the prohibition on Navigators, Licensed Utility Counselors (CACs), and non-Navigator help suppliers (“Assisters”) from going door-to-door to assist shoppers enroll in medical health insurance. CMS asserts that prohibiting door-to-door outreach inhibits the power to help shoppers with restricted capability to journey, whether or not as a consequence of disabilities, being immunocompromised, or a scarcity of transportation.

Advocacy organizations shared a wide range of opinions concerning this proposal. Group Catalyst and NHeLP assist the repeal of the prohibition, citing the crucial function assisters can play in Market enrollment, notably as tens of millions of individuals transition off of Medicaid. NHeLP factors out that door-to-door help would assist enroll hard-to-reach people and households, together with communities with out constant expertise entry, in addition to shoppers who don’t communicate English and people with disabilities.

Nonetheless, different advocacy teams warn that door-to-door enrollment help, which can require people to share delicate private and monetary data with strangers, would open the door for scams, reminiscent of identification theft. Households USA notes that though door-to-door outreach will be useful for reaching particular communities, many People can’t distinguish true Navigators and assisters from rip-off artists. ACS-CAN additionally flags that individuals will doubtless reply negatively to somebody at their door showing to “promote insurance coverage.” These organizations opposed this coverage, urging that, if CMS goes ahead with the proposal, the company ought to implement anti-fraud safeguards, reminiscent of in depth public well being training on the way to determine official assisters and a requirement for assisters to offer paper documentation the buyer. Advocacy organizations in favor of lifting the prohibition additionally instructed establishing anti-fraud protections.


If a shopper stays eligible for certified well being plan (QHP) protection however doesn’t actively select a plan throughout re-enrollment, a “re-enrollment hierarchy” prioritizes retaining the buyer in the identical plan or, if that plan is just not obtainable, on the identical metallic degree. Within the proposed 2024 NBPP, CMS offered new insurance policies Marketplaces may use to robotically re-enroll sure Market shoppers into QHPs designed to assist shoppers maximize potential out-of-pocket price financial savings. Below this method, bronze plan enrollees who’re income-eligible for cost-sharing reductions (CSRs) can be robotically moved to a silver plan, to allow them to enroll in a plan eligible for cost-sharing discount subsidies. If an enrollee’s QHP is not obtainable, CMS proposed taking the buyer’s present supplier community into consideration when re-enrolling the buyer into a special QHP. As well as, CMS requested feedback on whether or not Marketplaces ought to take into account web premium and whole out-of-pocket prices when re-enrolling shoppers in future years.

A number of advocacy organizations in our pattern a minimum of partially assist these adjustments. NHeLP cites analysis indicating that 30 p.c of households robotically renewed into protection can be higher off in a special plan. Group Catalyst applauded the proposal, in addition to CMS’ effort to prioritize putting folks into plans with comparable supplier networks, noting that doing so may mitigate shoppers’ threat of incurring medical debt in the event that they have been to unintentionally obtain care from out-of-network suppliers. Equally, ACS-CAN underscores the significance of sustaining in-network relationships for most cancers sufferers in lively therapy and for survivors of uncommon cancers. NHeLP, nevertheless, suggests prioritizing affordability somewhat than continuity of carriers and product traces when shoppers don’t affirmatively select a brand new plan, whereas Group Catalyst recommends that CMS deal with web premiums and anticipated cost-sharing as separate variables for re-enrollment in future rulemaking.

Standardized and Non-Standardized Plans

Within the 2023 plan yr, CMS instated a requirement that insurers providing QHPs within the Federally Facilitated Market (FFM), or in State-based Marketplaces use the federal platform (SBM-FP), should additionally provide standardized—and simply comparable—cost-sharing and profit designs wherever they provide “non-standardized” plans. Because of this for each insurance coverage product, at each metallic degree, and in each geographic market an insurer affords non-standardized plans, they need to additionally provide a standardized plan.

For 2024, CMS intends to retain the standardized plan requirement with some modest adjustments, reminiscent of not requiring insurers to supply a standardized plan on the non-expanded bronze degree, and requiring insurers to position lined medicine into applicable cost-sharing tiers. In a extra vital change, nevertheless, CMS proposed limiting the variety of non-standardized plan choices insurers might provide. Below the proposed rule, insurers providing QHPs within the FFM and SBM-FPs would have the ability to provide solely two non-standardized plans per product community sort and metallic degree (apart from catastrophic plans) in any service space. CMS additionally supplied an alternate method to this numerical restrict on non-standardized plans, which might require insurers’ choices to be “meaningfully totally different” from each other. Below this method, CMS would group plans by county, insurer, metallic degree, product community sort, and deductible integration, requiring QHPs inside every group to have a minimum of a $1,000 distinction in deductibles.

The entire shopper advocacy teams in our pattern applaud the proposals to simplify the buyer purchasing expertise by persevering with the standardized plan requirement and limiting “selection overload,” which might happen when shoppers face too many plan choices and wrestle to distinguish between merchandise. NHeLP notes that “the standard understanding that extra is best for the buyer doesn’t maintain true within the Market. Quite the opposite, the excessive variety of plan choices usually results in confusion amongst buyers, which in flip offers approach to shopper errors throughout plan choice.” Some organizations, reminiscent of Group Catalyst, NHeLP, and ACS-CAN urge CMS to each restrict the variety of non-standardized plans insurers may provide and apply a significant distinction normal to a number of QHP choices.

A Notice on Our Methodology

This weblog is meant to offer a abstract of feedback submitted by shopper advocacy organizations. This isn’t supposed to be a complete evaluate of all feedback on each provision within the Discover of Profit and Fee Parameters proposed rule, nor does it seize each element of the reviewed feedback. To view extra stakeholder feedback, please go to


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