MT| The Montana CSI Advisory Memorandum dated May 26, 2026 explains changes in Qualified Health Plan certification requirements resulting from the 2027 Final Notice of Benefit and Payment Parameters, focusing on how the final CMS rule diverges from the proposed rule for PY 2027. It confirms that issuers must report detailed cost-sharing reduction (CSR) loading information in the Unified Rate Review Template and Part III Actuarial Memorandum, continue following existing state-mandated benefit defrayal rules because the new federal framework starts in PY 2028, and may offer non-standardized portfolios without standardized plan options beginning in PY 2027. The memo clarifies that CMS did not finalize proposed multiyear catastrophic plans or higher catastrophic maximum out-of-pocket limits until PY 2028, but does allow certain bronze plans to exceed the standard annual limitation on cost sharing if at least one compliant bronze plan is also offered in the same service area. It also notes that the existing essential community provider network adequacy threshold remains at 35 percent, Montana retains its limited exception for stand-alone dental plans, and emphasizes that the document is informational only and does not alter underlying state or federal law, advising issuers to review all applicable requirements and seek independent legal counsel as needed.
Montana Updates QHP Rules for 2027: What Health Insurers Need to Know
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