CMS Final Letter to Issuers
It's that time of year again. CMS has released their final guidance bulletin for Health Insurance issuers hoping to sell plans on the ACA marketplace for 2025. I'm diving in to try sort out the implications of this year's changes.
Patrik Gammon
4/16/20241 min read
On April 17, 2024, the Center for Medicare and Medicaid Services (CMS) released their 2025 Final Letter to Issuers. This annual document provides essential guidance for health insurance issuers operating on the Federal Health Insurance Exchange. The release of this final letter marks a critical phase for insurers, as they now have the definitive rules and requirements necessary to finalize their qualifying health insurance plans for 2025. As someone who regularly files Form and Binder filings for QHPs, I am noting some things that stick out to me this year.
Standardized Plan Options
In 2025, the approach to standardized plan options remains largely consistent with prior years, with references to earlier issuances in 2023 and 2024 for a summary of requirements. There are minor updates to the plan designs to ensure that the actuarial values are within the permissible range for each metal level.
Non-Standardized Plan Option Limits
A significant change is the reduction of the allowable non-standardized plan options issuers can offer—from four per product network type, metal level, and service area (in 2024) to two (in 2025). This limit applies irrespective of the inclusion of dental and/or vision benefit coverage. This is consistent with CMS's recent approach of limiting the number of duplicative products on the exchange.
Telehealth for Time and Distance Standards
CMS has again reiterated that more research would be needed before they can determine whether counting telehealth is appropriate for purposes of a QHP meeting network adequacy time and distance standards. Because time and distance standards are a metric related to physical access, taking telehealth into account in measuring that metric is complex. While this has been reiterated many times, it is worth taking into account that MHPAEA has been a primary focus for many state Departments of Insurance. Telehealth for Mental Health Services is a growing industry with companies like Betterhelp and Teledoc consistently growing revenue streams by 10-15% YoY.