On March 13, 2026, CareFirst BlueCross BlueShield submitted comments in response to the Centers for Medicare & Medicaid Services’ (CMS) Notice of Benefit and Payment Parameters for 2027 proposed rule. In our letter, we provided feedback on several proposals, including those related to cost-sharing reduction load reporting justification, state defrayal of certain mandated benefits, expansion of catastrophic plans, certification of non-network plans, improper payment measurement in state-based exchanges, and deferral of network adequacy standards to state exchanges.
While we supported some proposals, such as the defrayal of state-mandated benefits, we emphasized that others could undermine market stability and create consumer confusion, particularly related to catastrophic and non-network plans. We also noted that new cost-sharing reduction load justification requirements could increase administrative burden for issuers.