The AHA commented March 13 on the Centers for Medicare & Medicaid Services’ proposed Notice of Benefit and Payment Parameters for 2027. The AHA supported CMS’ interest in creating more innovative coverage options but expressed concern that non-network plan attestations are not a strong enough guardrail to ensure adequate payments and patient access to care. The AHA also expressed concerns about expanding access to catastrophic plans, noting that they do not provide true protection against catastrophic costs. Additionally, the AHA shared recommendations on the maximum annual limit on cost-sharing, network adequacy standards and essential community provider requirements, and the medical loss ratio. 

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