policy
ACAP Comments on HHS Notice of Benefit and Payment Parameters for 2027
March 13, 2026
Robert F. Kennedy
Secretary
Department of Health and Human Services
Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
Peter Nelson
Deputy Administrator and Director
Center for Consumer Information and Insurance Oversight
Centers for Medicare & Medicaid Services
Submitted electronically via: www.regulations.gov
Re: Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2027; and Basic Health Program
Dear Deputy Administrator and Director Nelson,
The Association for Community Affiliated Plans (ACAP) respectfully submits comments in response to the proposed rule updating the Notice of Benefit and Payment Parameters for 2027.
ACAP is a national trade association representing 90 not-for-profit Safety Net Health Plans (SNHPs). Our member plans provide coverage to more than 30 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP), Medicare Special Needs Plans for dually eligible individuals, the Basic Health Program, and the ACA Marketplaces. Of ACAP’s SNHP Member and Partner Plans, 36 offer qualified health plans (QHPs) or Basic Health Program (BHP) plans, and our plans serve over 2 million enrollees in the ACA Marketplaces.
ACAP has chosen to respond to a subset of proposals in the update of the Notice of Benefit and Payment Parameters for 2027 that are particularly relevant to SNHPs. ACAP appreciates the Administration’s desire to strengthen the integrity of the Marketplaces; our comments focus on ensuring market stability for SNHPs and the consumers they serve. ACAP member plan enrollees are generally low-income populations, and we would like to emphasize that the comments herein support SNHPs in their efforts to serve their communities.