ACAP Comments on the Notice of Benefit and Payment Parameters for 2025

On January 8, ACAP submitted comments on the Notice of Benefit and Payment Parameters for 2025.

ACAP chose to respond to a subset of proposals that are particularly relevant to Safety Net Health Plans (SNHPs). ACAP shared appreciation for 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 ACAP emphasized that the comments  support SNHPs in their efforts to serve their communities.

ACAP respectfully submitted comments on the following areas:

  • Essential Health Benefits
  • Prescription Drug Proposals
  • Standardized Plan Options
  • Non-Standardized Plan Options
  • CO-OP Loan Terms
  • Network Adequacy Standards
  • Web Broker Requirements
  • Direct Enrollment Entity Requirements
  • Failure Reconcile Process
  • Auto Re-Enrollment Hierarchy
  • Premium Payment Deadline Extensions
  • Initial and Annual Open Enrollment Periods
  • Special Enrollment Periods
  • Termination of Coverage or Enrollment for Qualified Individuals
  • Exchange Establishment and Operations
  • Reinsurance, Risk Corridors, and Risk Adjustment
  • State Flexibility in Use of Income and Resource Disregards for Non-MAGI Populations

Read the letter in full, including expanded comments, via the sidebar to the right.