AHA Responds to CMS Proposed Parameters for 2027

The American Hospital Association (AHA) recently responded to the Centers for Medicare & Medicaid Services' (CMS) proposed Notice of Benefit and Payment Parameters for 2027. Representing approximately 5,000 healthcare entities, the AHA emphasized the need to balance market innovations with consumer protections to ensure patients have access to affordable care. The AHA highlighted critical issues in CMS’s proposals, addressing areas such as non-network plans, catastrophic coverage, and out-of-pocket maximums.

CMS's proposal to allow non-network plans in marketplaces has been met with cautious support from the AHA. The association stressed that innovative plans could thrive if accompanied by robust consumer protections, ensuring provider agreements are in place and financial risks are clearly communicated. In contrast, the AHA expressed concerns about expanding catastrophic plans, suggesting that high deductibles may jeopardize coverage for low-income individuals.

Furthermore, the AHA warned against the significant increase in maximum cost-sharing proposed for 2027, stating that it could make coverage less affordable and increase patient financial burdens. Additionally, the proposal to give states more flexibility in setting network adequacy and Essential Community Provider (ECP) standards was critiqued. The AHA supports increased state oversight but is concerned that relaxing ECP requirements could limit access to care in underserved regions.

The association also highlighted the importance of maintaining a strong Medical Loss Ratio (MLR) to ensure premiums are primarily allocated to patient care. Vertical integration within health systems may misappropriate premium funds, ultimately affecting market competition and patient benefits. The AHA remains dedicated to collaborating with CMS to safeguard affordable healthcare and effective marketplace operations.