On November 12, 2024 the National Women’s Law Center submitted a comment on the proposed Notice of Benefits and Payment Parameters for 2026, an annual rule by the Department of Health and Human Services (HHS) implementing various aspects of the Affordable Care Act.

Among other recommendations, we urged HHS to:

  • Require all Exchanges to provide an annual Failure-to-Reconcile (FTR) notice for each year that a consumer a fails to reconcile their Advance Premium Tax Credits (APTC)
  •  Adopt the proposed fixed-dollar and gross premium payment threshold options
  • Strengthen enforcement against agents, brokers, and lead agents who engage in unauthorized Marketplace activity
  • Allow assisters to refer consumers to financial programs to reduce medical debt
  • Adopt the proposed requirement for meaningfully different standardized plan options
  • Adopt the proposed qualified health plan (QHP) certification denial and essential community provider (ECP) certification review authority
  • Adopt the proposed pre-exposure prophylaxis (PrEP) factor for risk adjustment models.

Our full comment can be found here.