On Sept. 20, the Centers for Medicare and Medicaid Services (CMS) finalized “Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond” (CMS-9906-F), which

  • Extends open enrollment for Plan Year 2022 on the federal exchanges to run from Nov. 1 – Jan. 15

  • Expands Navigator programs

  • Reverts Section 1332 state innovation waivers to pre-2018 requirements

  • Allows individuals to change metal level of Qualified Health Plan (QHP) coverage during the plan year as a result of a change in their personal income.

NADP submitted comments on the proposed rule in July. (See below).

The final rule responds to NADP concerns over the potential effect of metal level changes on enrollment in standalone dental plans:

“HHS clarifies that this proposal, and the resulting final rule, do not newly permit Exchange enrollees to change to a plan of a different metal level or make policy changes to plan category limitations for existing special enrollment periods. Rather, the new rule establishes a plan category limitation to address a newly created special enrollment period triggering event and makes a small technical clarification to the preceding paragraph, as further discussed earlier in this preamble.

Further, Health and Human Services (HHS) has discussed and extensively investigated concerns about accidental standalone dental plan disenrollment due to a change in medical QHP and has not found this to be a problem in practice for enrollees, who are always offered the opportunity to select or re-select their standalone dental plan after completing medical QHP selection. Finally, HHS clarifies that the new monthly special enrollment period does not change or expand eligibility requirements for other special enrollment period qualifying events at § 155.420(d).” (p. 99).”

Please feel free to comment with any thoughts and questions by emailing Sr. Government Relations Analyst Owen Urech.


Press Release

Final Rule Full Text

NADP Letter on Proposed Rule

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