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Statement of ACAP CEO Margaret A. Murray on 2027 Notice of Benefit and Payment Parameters
FOR IMMEDIATE RELEASE: May 19, 2026
FOR MORE INFORMATION: Marty Johnson, (202) 420-7424; mjohnson@communityplans.net
Statement of ACAP CEO Margaret A. Murray on 2027 Notice of Benefit and Payment Parameters
WASHINGTON — Margaret A. Murray, chief executive officer of the Association for Community Affiliated Plans (ACAP), issued the following statement on the recent release by the Centers for Consumer Information and Insurance Oversight (CCIIO) on the Notice of Benefit and Payment Parameters (NBPP):
“We have a number of concerns with this rule, starting with its timing alone—our member plans are already well into the process of constructing their 2027 bids. A notice of this scope arriving so late in the plan year cycle doesn’t just create administrative headaches, it creates real risk that consumers will feel the downstream effects of decisions made under compressed timelines and incomplete regulatory guidance. Plans need time to operationalize policy changes in ways that protect consumers and preserve market stability. Releasing the NBPP in the middle of the bid cycle is not a sustainable practice.
“That said, there are some laudable provisions of the NBPP. First among them are the stronger broker and marketing protections, which are a welcome improvement. Consumers deserve to know that the people helping them choose coverage are working in their interest.
“The treatment of non-network plans, however, raises significant concerns. While finalizing that framework for 2028 rather than 2027 gives plans a little extra time to plan, it nevertheless opens the door to plans that undermine the basic premise of Marketplace plans—that they provide access to care at an affordable, predictable cost. By their structure, these plans can leave their members stuck with surprise bills and higher out-of-pocket costs should they require virtually any kind of care.
“Additionally, allowing multi-year catastrophic coverage without annual verification bodes poorly for market stability and erodes consumer protections. Healthier enrollees drawn out of the regular Marketplace miss out on the comprehensive coverage with premium tax credits to make them more affordable. Consumers may well put off needed care because they are forced to choose between seeing a doctor to check on an unexplained lump or putting gas in their car. And when care gets delayed, everyone pays the price.
“ACAP looks forward to further engagement with CMS and CCIIO leadership in the months ahead to address the open questions this rule raises – and the others it leaves on the table.”
About ACAP:
ACAP is the national trade organization representing 91 health plans, which collectively provide health coverage to more than 30 million people. 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 communityplans.net.
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