Regulatory NewsBREAK: CMS Issues Notice of Benefit and Payment Parameters

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On May 18, 2026, the Centers for Medicare and Medicaid Services (CMS) published the final Notice of Benefit and Payment Parameters for 2027 (NBPP).

The NBPP updates Affordable Care Act (ACA) marketplace standards and payment parameters for plan year 2027, qualified health plan (QHP) standards, risk adjustment, enrollment policies, Basic Health Program (BHP) policies, and implementation of provisions from the One Big Beautiful Bill legislation (Pub. L. 119-21).

CMS is finalizing several policies on program integrity and oversight across ACA marketplaces, including: 

  • expanded oversight and compliance standards for agents, brokers, and web-brokers; 
  • implementation of the State Exchange Improper Payment Measurement (SEIPM) framework; and  
  • enhanced enforcement tools, including civil money penalties for noncompliant entities. 

The NBPP finalizes 2027 benefit year federally-facilitated exchange (FFE) and state-based exchange – federal platform (SBE-FP) user fee rates of 1.9 percent and 1.5 percent of total monthly premiums, respectively.

The NBPP adds a scaling factor to the HHS-operated risk adjustment and risk adjustment data validation (HHS-RADV) error estimation methodology. CMS emphasizes risk adjustment as a key market stabilization mechanism. 

CMS revises provider network adequacy and Essential Community Provider (ECP) standards, adds state flexibility in conducting network adequacy reviews, and permits certification of certain non-network QHP options. 

The NBPP allows catastrophic plans to maintain plan terms for up to 10 consecutive years and revises cost-sharing flexibility standards for catastrophic and bronze coverage options. 

The NBPP updates standards governing state-required benefits that exceed Essential Health Benefit (EHB) requirements and related state defrayal obligations. 

The NBPP implements statutory changes affecting premium tax credit (PTC) eligibility and Exchange enrollment for noncitizens and consumers enrolling through certain income-based special enrollment periods (SEPs). 

CMS finalizes revisions affecting BHP payment methodologies and enrollee treatment within federal BHP funding calculations. 

Effective Date: July 20, 2026.

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