ACAP Comments on 2020 Notice of Benefit and Payment Parameters

FOR IMMEDIATE RELEASE: February 20, 2019
FOR MORE INFORMATION: Jeff Van Ness, (202) 204-7515


WASHINGTON—Margaret A. Murray, Chief Executive Officer of the Association for Community Affiliated Plans (ACAP), today made the following statement on the proposed 2020 Notice of Benefit and Payment Parameters (NBPP), on which comments from stakeholders were due today:

“We’re grateful for the opportunity to comment on the 2020 NBPP.”

“We are appreciative of the Administration’s decision to defer commentary on ‘silver-loading’ premiums for the time being. The practice is, admittedly, far from an ideal solution, but it is the best response the market has developed to the Administration’s continuing refusal to reimburse plans for cost-sharing reduction payments. We look forward to discussing better solutions with CMS and Congress.

“We also agree with actions CMS proposes regarding enrollment procedures including the addition of certain special enrollment periods, enhanced oversight of brokers, and measures to differentiate between ACA-compliant and noncompliant health plans.

“ACAP questions at this time the choice CMS made to revise the methodology for calculating the premium adjustment percentage, which is used to help determine the level to which a Marketplace member would receive Federal subsidies. The last two benefit years have seen dramatic changes in business climate and shifting ground rules. Adding another variable to the Marketplace environment when there are already so many in the air is a choice we urge CMS to reconsider.

“It’s also disappointing that the Administration has declined to include Medication-Assisted Treatment for opioid addiction treatment as a mandated benefit. CMS should reconsider this. Given that the opioid crisis has been declared a public health emergency by this Administration, it seems odd to categorize this benefit as ‘nice to have’ instead of ‘need to have.’”

About ACAP
ACAP represents 60 Safety Net Health Plans, which provide health coverage to more than 20 million people in 29 states. Safety Net Health Plans serve their members through Medicaid, Medicare, the Children’s Health Insurance Program (CHIP), the Marketplace and other publicly-sponsored health programs. For more information, visit


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