HHS Releases Notice of Benefit and Payment Parameters for 2022, Part Two

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Recently, the United States Department of Health and Human Services (HHS) released the Notice of Benefit and Payment Parameters for 2022 final rule, part two (scheduled to be published on May 5, 2021). This final rule finalizes some of the standards included in the proposed rule for states, exchanges, non-federal governmental plans, issuers in the individual and small-group markets, and web brokers.

Lowering Out-of-Pocket Costs

Due to an “overwhelming” number of comments received, HHS did not finalize the proposed Premium Adjustment Percentage Index (PAPI), maximum annual limitation on cost sharing, or the required contribution percentage, as calculated using the National Health Expenditure Accounts (NHEA) projections and estimates of private health insurance premiums. Instead, HHS is finalizing calculation of the PAPI and cost-sharing parameters using the NHEA projections of average per-enrollee employer-sponsored insurance (ESI) premium. This is the same measure used for benefit years 2015 to 2019.

Therefore, the final premium adjustment percentage index for 2022 is 1.3760126457, the final required contribution percentage for 2022 is 8.09%, and the final maximum annual limitation on cost sharing for 2022 is $8,700 for self-only coverage and $17,400 for other-than-self-only coverage. This finalizes a maximum annual limitation on cost sharing that is $400 below what the Centers for Medicare and Medicaid Services (CMS) proposed in November 2020.

Risk Adjustment

Also in the final rule, HHS opted to not finalize many of the proposed updates to the RA model specifications, including not finalizing changes to the RA models to include a two-stage specification in the adult and child models, to replace the existing severity illness indicators in the adult models with new severity and transplant indicators with hierarchical condition category (HCC) counts factors in the adult and child models, nor to modify the enrollment duration factors in the adult models. Instead, HHS will release a technical paper (at a date to be determined) with more data and analysis on the impact of the proposed changes.

However, in the final rule, HHS did finalize the continuation of the pricing adjustment for hepatitis C drugs that has been in place since the 2020 benefit year. HHS also finalized RA reporting requirements for issuers of RA-covered plans who choose to provide temporary premium credits, if permitted by HHS during a future public health emergency.

HHS also finalized the policy whereby it will use the three most recent consecutive years of enrollee-level EDGE data that are available in time for incorporating into the coefficients in the proposed rule and to not update the coefficients for additional years of data between the proposed and final rules if an additional year of enrollee-level EDGE data becomes available. This means that for the 2022 model recalibration, enrollee-level EDGE data from the 2016, 2017 and 2018 benefit years will be used, the same data years used for the 2021 model recalibration.

Web Broker Display Requirements

In finalizing the rule, HHS will not create an exception to existing requirements that web broker non-exchange websites to display certain QHP comparative information. HHS noted its belief “that the display of more QHP comparative information on web broker non-exchange websites is in the best interest of consumers to aid them in comparing QHP options without having to potentially navigate to multiple websites.”

Pharmacy Benefit Manager (PBM) Transparency

HHS did finalize a rule to allow for collecting prescription drug data directly from PBMs. The data collected will be used to enhance HHS’s understanding of the true cost of prescription drugs provided in exchange plans, and to shed light on the role that PBMs play in their cost. The data collected will be kept confidential and may only be disclosed for limited purposes outlined in statute.

Additional Rulemaking

CMS expects to release additional rulemaking for the 2022 payment notice later this year.

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