Today, FAH submitted comments to CMS regarding its Notice of Benefit and Payment Parameters for 2024 Proposed Rule. FAH comments expressed support for numerous provisions in the Proposed Rule that would focus on helping consumers access and maintain coverage and promoting health equity. 

Conversely, FAH comments warned that policies that artificially limit the plan options available to consumers through the Exchanges are not consistent with robust consumer choice and therefore FAH does not support CMS’s proposal to limit the number of non-standardized plan options that a Qualified Health Plan (QHP) can offer.

FAH further recommended that to the extent that CMS considers adopting a meaningful difference standard for plan offerings, CMS should recognize that differences in provider network composition are in fact meaningful and to ensure that issuers retain the flexibility to offer both narrow and broad network versions of otherwise similar plans.  Other FAH comments supported proposals to extend network adequacy requirements more broadly and consistently to QHP issuers and strengthen essential community provider standards. 

You can read the entire comment letter here.