Customer Advocacy Groups Weigh in on CMS’s 2025 Notice of Benefits and Payment Parameters

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The Centers for Medicare and Medicaid Services (CMS) released its proposed Notice of Benefit and Payment Parameters (NBPP) for plan year 2025 last November.

In response, the Center on Health Insurance Reforms began a three-part blog series in which they asked different stakeholder groups their opinions on the new parameters.

The first part examined opinions from brokers and health insurers and comments were submitted by eight groups including Cigna and CVS Health.

The second part, published this week, focused on five consumer advocate groups: AARP, the American Cancer Society Action Network, Community Catalyst, Families USA and the National Health Law Program.

CMS requires that for plan year 2025, state-based marketplaces (SBMs) create network standards at least as strict as federally facilitated marketplace plans (FFM), focusing on the time and distance enrollees travel to receive care.

All groups supported this decision, and Community Catalyst and Families USA took things a step further and suggested marketplace plan appointment wait time standards be applied to SBMs. Families USA also asked that FFM standards extend to language access, cultural competency, and accessibility for enrollees with disabilities.

Insurers offering plans on Healthcare.gov will also be limited to offering two non-standardized plan options per area in three categories: product network type, metal level and products including dental and vision coverage. Exceptions will be made for those with chronic conditions.

AARP was the only group supporting the two-plan limit and the exception for chronic and high-cost conditions.

Families USA reported that they needed more information about the design of non-standardized plans and asked CMS if patients with chronic conditions are actually enrolling.

Enrollment periods have also changed in the 2025 NBPP and all groups surveyed agreed with the decision to require SBMs to align their coverage dates with the FFM.

The new CMS proposal also requires SBM call centers to be adequately staffed so that members can get help from an employee rather than an automated system.

The groups agreed with this change and the NHeLP and Community Catalyst asked for language diversity, disability access and modifications for enrollees who work during business hours.

There was some debate among the groups when it came to the proposed changes with essential health benefit (EHB) benchmarks.

Under the new rules, states would no longer have to defray the new benefit mandate if it is already part of that state’s benchmark plan.

States would also be allowed to change EHB benchmarks that exceed the ones set by the CMS in 2017 and update their typicality standard. This means states could adopt benchmarks more similar to employer-based plans.

Community Catalyst requested that CMS synchronize plan dates for the two changes.

While NHeLP generally agreed with the changes, they worried about the CMS’s legal interpretation of the EHB standards of the Affordable Care Act.