Understanding Network Adequacy Changes – and Potential Impact on Clients

Health care network concerns are real. There are many potential issues for your clients. “Ghost networks” is one. (That’s when directories list providers are not actually available to patients.) Others include few in-network participants. Delays getting an appointment. Long wait times at the appointment. Unexpected out-of-network referrals. Excessive costs. These are all potential challenges for clients.

Health plans must have an adequate number of providers. And they must include different specialties. The goal is to ensure care for members within a reasonable distance and without delay. Guidelines also require accurate provider directories.

Changes from the Centers for Medicare & Medicaid Services (CMS) could be ahead in 2027.

What Could Change With the 2027 NBPP?

CMS has released proposed 2027 Notice of Benefit and Payment Parameters (NBPP). These outline updates for ACA plans. Potential changes include expanded plan designs. They also include certification of non-network plans. Plus, modifications to network adequacy, accountability, and eligibility verification.

CMS is proposing:

  • Multi-year catastrophic plans of 1-10 years
  • Expanded hardship exemptions for those 30+
  • Repeal of standardized plan requirements
  • Repeal limits on non-standardized plans
  • Allowing low-deductible plans with higher out-of-pocket limits
  • Certifying innovative non-network plans
  • Enhanced oversight for eligibility
  • Expanded conduct standards for agents/brokers

Some potential downsides of the proposed changes include:

  • Reduced network oversight and non-network plan certification could restrict provider access.
  • Narrower networks and non-network models could exclude independent specialists.
  • Higher out-of-network costs could push clients to delay specialty care.
  • Increased plan variability could create gaps for some services.
  • Changes to EHB subsidy policy could narrow coverage options in some states.

Like many, I applaud changes that could lead to lower premiums. We all want expanded choices and more accurate provider directories. Changes to strengthen ACA Marketplace integrity are admirable. However, innovation and flexibility changes could undermine access to timely and affordable care. Time will tell what changes are adopted by CMS and supported by Congress.

How Much Can You Earn as an Insurance Broker?

Find out what you can be earning as an insurance agent in our handy, up-to-date salary guide. Produced by our in-house experts, this resource is bound to help you in advancing your career.

Word & Brown Salary Guide
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