Medicaid Updates
- A federal judge declined to grant a preliminary injunction around implementation of CMS’s work requirement regulations. This does not preclude a ruling against the regulation later on but as of today, states will be required to implement the work requirements, including medical frailty definitions, as conveyed in CMS’ regulation.
- CMS released a proposed regulation around implementing provisions of the reconciliation bill that limits provider and payer related taxes. Part of the rule includes a provision that expands the limitations on taxes to include taxes on commercial insurers, which could affect other programs beyond Medicaid such as Marketplace operations and reinsurance programs. Lina Rashid has a good summary here
- CMS also released a toolkit to improve monitoring and reduce spending on Applied Behavior Analysis services. You can read more about it here
Medicare Updates
- CMS announced it will end the temporary Part D Premium Stabilization Demonstration after 2026, allowing the market to operate without federal premium subsidies beginning in 2027. The result will be an increase in Part D premiums for seniors in 2027.
- CMS announced it will expand its Joint Hip model to include most hospitals. Beginning in January 2028, most hospitals will be required to participate in the Comprehensive Care for Joint Replacement Expanded (CJR-X) Model, which is part of the FY 2027 Inpatient and Long-Term Care Hospital Prospective Payment System Final Rule
ACA Updates
- https://www.cms.gov/files/document/plan-year-2027-standardized-plan-option-plan-designs.pdf CMS released guidance this week on implementing the Columbus II ruling, specifically around standard plans. Issuers in states where HHS operates the Marketplace (i.e., Healthcare.gov states) will be required to offer standard plans and have limits on their non-standard plans.
- This stems from a federal judge’s ruling against the 2027 Notice of Benefit and Payment Parameters (Columbus II). A coalition of states sued over similar items in a different venue. Additionally, a hearing was scheduled in late October over litigation around the Marketplace Integrity Rule (Columbus I). It is possible that there could be a ruling that could affect 2027 experience. Overall, there are four separate ongoing lawsuits against CMS related to the Program Integrity Rule and 2027 NBPP.
