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CMS Proposes 2025 Notice of Benefit and Payment Parameters

The Centers for Medicare & Medicaid Services (CMS) published its annual proposed changes to benefit and payment parameters for federal health care marketplaces, state-based marketplaces on the federal platform (SBM-FPs), and now state-based marketplaces.

State Marketplaces

CMS proposes several changes to state marketplace requirements to better align them with federal marketplace requirements:

  • Beginning in 2025, requiring state marketplaces and SBM-FPs to establish and impose quantitative time and distance qualified health plan network adequacy standards that are at least as stringent as those on the federal marketplace.
  • Standardizing open enrollment dates for all marketplaces from Nov. 1 to Jan. 15.
  • Improvements for state selection of essential health benefit (EHB)–benchmark plans.

Medicaid Provisions

The proposed rule also contains three Medicaid provisions:

  • States will have greater flexibility to adopt income or resource disregards in determining financial eligibility for non–modified adjusted gross income populations (blind or disabled people who qualify for Medicaid regardless of income).
  • State Medicaid agencies and marketplaces will be required to pay to access income data via the Verify Current Income Hub Service.
  • State-mandated benefits will not be considered “in addition to EHB” if the mandated benefit is an EHB in the state’s EHB-benchmark plan. This might affect state basic health plans and Medicaid alternative benefit plans.

CMS will maintain its approach to streamlining the plan selection process with standardized plans but proposes an exception for the number of non-standardized plan options that reduce cost and increase benefits for chronic conditions. CMS has made no changes to essential community provider requirements.

The public will have 45 days to submit comments. Comments are due Jan. 8, 2024.

America’s Essential Hospitals is analyzing the proposed rule and will send members a detailed Action Update in the coming days.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Julie Kozminski is a senior policy analyst at America's Essential Hospitals.

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