Predictions On The Proposed 2024 Exchange Rule – Part 2

Predictions On the Proposed 2024 Exchange Rule Health Policy Trends To Watch

Will Qualified Health Plans on the Federally-facilitated Marketplace see Appointment Wait Times added as a network adequacy requirement? Let’s discuss it!

In Part 2 of our Regulatory Review, Zach Snyder and Kate Deiters continue to share our predictions for the proposed Notice of Benefit and Payment Parameters rule for 2024.


Zach: The other issue you brought up was related to Appointment Wait Times. And again, in this year’s Notice of Benefit and Payment Parameters (NBPP), the Centers for Medicare & Medicaid Services (CMS) indicated that they will do a new wait time proposal this coming year—in the 2024 NBPP. They’re going to require health plans to ensure that their members have access to providers within certain specified wait time metrics.

We’ve seen other states do this as well. For example, ensure that your members have access to see a talk therapist within a ten-day timeframe.

CMS understands the challenge that health plans have in ensuring that requirement because health plans don’t really control what the provider does. So, they’re going to put these new requirements in place and in future years look to monitor and measure whether a health plan is actually meeting those requirements.

Kate: Is there anything that you could recommend for health plans out there that are trying to stay ahead of this trend or this curve?

Zach: CMS has indicated that health plans may use surveys or secret shoppers to measure and enforce this against health plans. So that seems to mean that health plans would be able to survey their provider network to ensure that the providers are actually meeting these wait times and use that as evidence of meeting compliance. But we don’t know for sure. We’re going to see more when the actual rule is out, likely in January of 2023. It would be finalized in the spring of 2023 and in effect, in January 2024.

Kate: Thank you so much, Zach. It’s super helpful to have that information. So everyone, be sure to add wait times to your What to Watch or Keep Your Eyes On lists. 


Predictions on the Proposed 2024 Exchange Rule

Zach Snyder and Kate Deiters of Quest Analytics are here to discuss the upcoming Proposed Exchange Rule for 2024. They share predictions for what may appear in the proposed rule—including telehealth, wait times, and health equity.

The Exchange Rule, also known as the Notice of Benefit and Payment Parameters (NBPP), is an annual rule that lays out the requirements for how health insurance exchanges must operate. 

The proposed rule is now available. Read our Executive Summary to get all the details. 

Watch Part 1

Watch Part 3