Association Comments on Non-Network Qualified Health Plans

In a March 13 letter, America's Essential Hospitals and other health care stakeholders shared concerns with the Centers for Medicare & Medicaid Services (CMS) about qualified health plan (QHP) certification. Specifically, the letter focused on CMS' proposal in the 2027 Notice of Benefits and Payment Parameters rule to allow non-network plans to receive QHP certification on the health care marketplaces.

Currently, QHPs are required to provide adequate access to care and have cost-sharing limits. However, non-network plans offer a set payment amount for covered services without contracting with providers, leaving patients subject to balance billing. The rule is unclear how non-network plans would meet these standards.

Before finalizing the non-network provision, the stakeholder group asks CMS to clarify:

• What constitutes adequate access and how that meets network adequacy requirements, including for essential community providers
• How CMS will enforce adequate access on an ongoing basis
• How patients will be protected from balance billing

Contact Director of Policy Rob Nelb at [email protected] or 202.585.0127 with questions.