Regulatory Joe

What the Delayed PY2027 NBPP Means for ACA Filing Operations

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This year's PY2027 NBPP didn't just arrive late. It compressed the entire ACA filing season for issuers nationwide.

CMS didn't finalize the rule until May 15, weeks after the QHP application window opened and past some states' own filing deadlines for rates, forms and binders.

In this episode, ClearFile President Joe Boyle breaks down what happened this filing season and what it means heading into plan year 2028.

This episode covers:

  • Why some states held their filing deadlines while others paused SERFF configuration until the rule was finalized
  • How the delayed QHP application window and HIOS access timelines created a second bottleneck for issuers
  • What a contingency implementation plan for plan year 2028 should include
  • Why health plan associations matter more in a year of regulatory uncertainty

    • Subscribe to Regulatory Joe for more insights on ACA filing operations, NBPP strategy and QHP compliance readiness.

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    Regulatory JoeBy ClearFile