MT| The Montana Advisory Memorandum, issued April 22, 2026, outlines 2027 plan year filing deadlines, template requirements, and review processes for all individual, small group, large group, and stand-alone dental issuers in Montana, including those on and off the FFE. It highlights federal 2027 NBPP proposed changes affecting actuarial tools, state-mandate defrayal, plan standardization, catastrophic and bronze designs, CSR “silver loading,” and network adequacy, while clarifying that CSI continues plan management but defers federal QHP network adequacy review to CMS. The memo also details how issuers must structure rate filings via SERFF/URRT (including new GLM/complex model support and CSR load reporting expectations), form and disclosure submissions, and nondiscrimination standards for EHB and prescription drug benefits. CSI sets out Montana-specific network adequacy templates for providers, facilities, and (if applicable) preferred pharmacies, and explains that rate, form, and template approvals are contingent on networks meeting both federal and state standards. Finally, it confirms CSI’s ongoing technical assistance role, complaint handling responsibilities, and provides contacts for forms/binders, rates, and network adequacy questions.
Key Points:
- Dual-track network adequacy: Clarifies that CMS will review federal QHP network adequacy while CSI conducts Montana network adequacy reviews using required provider/facility/pharmacy templates, with all networks resubmitted annually and approvals needed before completing rate, form, and template reviews.
- Filing calendar and scope: Specifies PY2027 filing dates for binders, forms, rates, CMS transfers, and change cutoffs for all Montana individual, small group, large group, and SADP products on and off the FFE.
- Federal 2027 NBPP highlights: Summarizes key proposed federal changes, including new URRT/AV tools, expanded state-mandate defrayal, elimination of standardized-plan and non-standardized-plan limits, catastrophic/bronze plan design changes, CSR loading rules, and updated network adequacy/ECP expectations.
- Defrayal and EHB nondiscrimination: Explains current and potential expanded state defrayal obligations, required defrayal data submissions, and directs issuers to avoid presumptively discriminatory EHB and prescription drug benefit designs (e.g., ASD age limits, tiering for high-cost chronic drugs) unless clinically supported.
- Rate and form filing mechanics: Describes SERFF-based URRT/RDT processes, content and placement of Parts I–III, reinsurance “with/without” rate requirements, new GLM/complex model checklist, CSR load documentation, and form/SBC/OOC/SOB checklist, readability, and redline expectations.
Click here to see April 22, 2026 MT Advisory Memorandum
Click here to Download the 2027 Network Adequacy Template Instructions
Click here to Download the 2027 Network Adequacy Master Facilities Workbook Instructions