Policy Brief

QHP Certification

New Network Adequacy Requirements

What You Need to Know About New CMS Compliance

New network adequacy requirements for Qualified Health Plan (QHP) certification are in—and we’ve got you covered with the details. The Department of Health and Human Services (HHS) released the Notice of Benefit and Payment Parameters (NBPP) for the PY2024 Final Rule. In addition, the Centers for Medicare & Medicaid Services (CMS) issued the 2024 Final Letter to Issuers in the Federally-facilitated Exchanges (also known as the 2024 Final Letter).

The NBPP and 2024 Final Letter included significant changes to network adequacy reviews of health plans and stand-alone dental plans (SADPs) applying to offer qualified health plans (QHPs) through Federally-facilitated Exchanges (FFEs) and State-based Exchanges on the Federal platform (SBE-FPs). In this brief, we discuss the new network adequacy standards and requirements for the 2024 plan year (PY 2024) and changes coming in the future.

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