Final 2027 Notice of Benefit and Payment Parameters Released
On May 15, 2026, the Centers for Medicare & Medicaid Services (CMS) released the final 2027 Notice of Benefit and Payment Parameters (NBPP). This critical annual rule modifies the policies governing federal and state exchanges under the Affordable Care Act (ACA). By retaining many proposed changes from February 2026, the rule affects the responsibilities of qualified health plans (QHPs), exchanges, and insurance brokers.
The rule primarily strengthens state discretion and expands coverage opportunities. However, CMS anticipates a decline in marketplace enrollment by 1.2 to 2 million in 2027 due to stricter eligibility verification processes. This shift may reduce subsidies and influence the enrollment decisions of healthier individuals.
A notable policy adjustment involves the expansion of catastrophic plans, previously accessible mainly to individuals under 30 or those with hardship exemptions. Catastrophic plan providers can now offer multi-year contracts up to 10 years, including additional preventive services before the deductible. Although proposed alterations to index rates or cost-sharing over multiple years weren't adopted, the out-of-pocket maximum for these plans will climb to 130% of the standard limit in 2028.
The final rule introduces crucial changes for non-network plans by allowing QHP certification starting in 2028. These plans must adhere to the No Surprises Act, ensure broad provider access, and prioritize clear consumer communication. Additionally, some 2025 Marketplace Integrity and Affordability rule policies are reinstated, with certain provisions delayed to 2028 to facilitate seamless implementation.
State-based exchanges (SBEs) gain increased flexibility, although CMS refrained from letting states depend solely on web-brokers for enrollment. The agency simplified SBE transition requirements to accelerate the process. States must ensure provider network sufficiency while enjoying autonomy to set standards without rigid time or distance criteria, as CMS defers network adequacy judgments to states with robust access programs.
The NBPP enforces measures against improper payments in state exchanges, necessitating data submissions from states to monitor payment integrity. Regarding Essential Health Benefits (EHBs), CMS halts EHB-benchmark plan reviews and bars routine non-pediatric dental services as EHBs. Additional state-mandated benefits post-2011 exceeding EHBs won't receive federal funding starting in 2028.
The elimination of standardized plan options from federal exchanges by 2027 grants issuers discretion over their continuation. Non-standardized plan limits will also be abolished. Essential Community Providers (ECPs) must maintain the existing inclusion threshold of 35%, though states may assume ECP certification responsibilities if criteria are met. The NBPP's delayed release compresses timelines for QHP applications due by June 10, 2026, challenging insurance providers and stakeholders to swiftly adjust to the finalized regulations.