policy
ACAP Comments on Notice of Benefit and Payment Parameters (NBPP) for 2026
On November 12, ACAP submitted comments to CMS’s Deputy Administrator and Director, Dr. Ellen Montz in response to the proposed rule updating the Notice of Benefit and Payment Parameters for 2026.
ACAP shared appreciation for the Administration’s desire to strengthen the integrity of the Marketplaces. ACAP chose to respond to a subset of proposals in the update that are particularly relevant to Safety Net Health Plans (SNHPs), including:
- Risk Adjustment: Hepatitis C
- Risk Adjustment: PrEP
- Risk Adjustment: Data Validation
- Failure to Reconcile
- Premium Payment Thresholds
- Preventing Issuer Insolvency
- Agent and Broker Misconduct
- Silver Loading
- AV Calculator
- Standardized Plan Options: Meaningful Difference Standard
- Non-Standardized Plan Option Limits
Read the full letter, including expanded comments, via the sidebar on the right.