Notice and prepping for 2020 open enrollment

The Notice for Benefit and Payment Parameters (NBPP) is an annual rule that the Center for Medicare and Medicaid Services (CMS) puts out. NBPP is the operational rule book for the Affordable Care Act. It determines what types of plans can be offered, how pricing is determined, when do things need to be approved, and whether or not Silver Loading is allowed or a Broad Load is required. This is all big stuff for the ACA markets.

Traditionally, NBPP is out in late fall. NBPP 2019 was out in early December 2017.

The 2020 NBPP has (finally!) cleared OMBhttps://t.co/I9nna6TF9K

— Ariel Cohen (@ArielCohen37) January 17, 2019

NBPP 2020 is still not available. It is moving through the regulatory process right now and depending on how different entities that still have to review the rule are funded, it could be coming out soon or it could still be a while.

I am not too worried yet. Insurers want as much time to make plans on a fixed rule set as possible. However, there is still time in the plan construction process. In 2017, the Trump Administration released a preliminary rule in mid-February that significantly altered several key benefit and actuarial parameters. The most notable change was increasing the allowable bands of de minimas variation in actuarial value for all metal plans. The final rule was issued in April, 2017. Insurers were able to alter their plan offerings to incorporate the new parameters without too much stress.

NBPP-2020 ideally should have been released for notice and comment around Halloween and the final rule should have ideally been out by the New Year. But as long as it is released in the near future and far more importantly as long as it does not contain massive policy changes like mandatory Broad Loading of CSR, insurers can roll with the punches and give their actuaries and plan designers more coffee as they deal with a less than timely partner.