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

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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.