The Centers for Medicare and Medicaid Services (CMS) released a draft of its 2018 Letter to Issuers in the Federally-Facilitated Marketplaces (Letter) on November 10, 2016. The Letter – updated annually – provides operational and technical guidance for issuers seeking to offer Qualified Health Plans (QHPs) and Standalone Dental Plans (SADPs) on Federally-Facilitated Marketplaces (FFMs) and State-Based Marketplaces on the Federal Platform (SBM-FPs).
As with the Proposed Notice of Benefit and Payment Parameters for 2018 (NBPP for 2018), the Letter was released earlier than in prior years and on the heels of an election that raises significant questions regarding the future of the Marketplaces and the Affordable Care Act generally. However, until changes are made, issuers must begin working on plans for which they will seek certification to be included on the Marketplaces in 2018, which will have to be submitted this Spring.
PCG subject matter experts created a summary of the Letter that focuses on policy changes related to the QHP certification process from prior years’ Letters. Many of the changes outlined are more by way of clarification and providing greater detail rather than departures from prior policy. Most policy changes mirror changes proposed in the Notice of Benefit and Payment Parameters for 2018 or other guidance and are not new to this Letter.
Regulators across the country are reviewing these provisions to understand the changes and how they will impact their regulation of health plans and the markets in their states. To better support states as they analyze the impact of the proposed guidance for 2018, we welcome you to share the summary with colleagues, clients and others. PCG also hosted a webinar on the Letter on November 22nd. Please email RRiso@pcgus.com for a recording of the webinar.