Proposed 2024 Payment Rule, Part 3: Exchange Operational Standards and APTC Policies

On December 12, 2022, the U.S. Department of Health & Human Services released a proposed rule to refine and update Plan Year 2024 standards for health insurers and Marketplaces under the Affordable Care Act (ACA). In addition to the proposed 2024 Notice of Benefit & Payment Parameters (NBPP), the Department also released the 2024 Draft Letter to Issuers, the 2024 Actuarial Value Calculator and Methodology, and guidance on annual adjustments to certain numerical payment parameters.In an article for the Health Affairs Forefront series “Following the ACA,” Jason Levitis summarizes components of the releases affecting Exchange operational standards and APTC policies, including the annual payment parameter guidance. The rule proposes changes to important Marketplace eligibility rules, including special enrollment periods, the “failure to reconcile” rule, and “data matching issues” related to income. It also adds flexibility to the process for states to establish a state-based Marketplace and proposes to slightly reduce the Exchange user fees for Marketplaces relying on healthcare.gov.