On April 30, the Centers for Medicare and Medicaid Services (CMS) filed “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2022 and Pharmacy Benefit Manager Standards,” an update to the rule finalized in January (Note: the Federal Register publication date for the rule was May 5).

The Rule finalizes changes to allow direct enrollment entities (DE) to offer certified off-exchange stand-alone dental plans alongside non-exchange dental plans. It also declines to allow independent purchase of dental plans on the federal marketplaces but does not rule out the possibility in the future. The update does not change the reduction in the user fee from the January final rule.

NADP submitted comments in December 2020 opposing the Enhanced Direct Enrollment (E-DE) method out of concern for the potential loss of coverage through the end of automatic renewal for exchange plans and consumer confusion about E-DE platforms.

Letter to Issuers

On, May 6, CMS also released the finalized version of the Plan Year (PY) 2022 Letter to Issuers on the Federally Facilitated Exchanges. In summary, the letter finalizes the proposed letter’s increase to the stand-alone dental plan (SADP) annual cost sharing limit to $375 for one child and $750 for two or more children.

NADP will continue to monitor CMS activity with respect to this final rule. Please contact Sr. Government Affairs Analyst Owen Urech with any questions.


Final Rule Text

NADP Comments on Proposed Rule

2022 Final Letter to Issuers

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