I addressed this in Part 3 of my look at the #NBPP2027 (w/a shout-out to @katie-keith.bsky.social & @mattafiedler.bsky.social, who did more comprehensive takes on it):

acasignups.net/26/02/19/cms...

CMS posts Proposed NBPP 2027. Be afraid; be very afraid. (Part 3) IMPORTANT: You have until March 13th to SUBMIT A PUBLIC COMMENT to CMS about any of the proposed changes listed below! It may not make any difference but believe it or not sometimes it does, even unde...

🚨 CMS posts proposed #NBPP2027. Be afraid; be very afraid. (Part 3 of 3)

At least you have until March 13th to submit public comment about these proposed changes, anyway...

acasignups.net/26/02/19/cms...

CMS posts Proposed NBPP 2027. Be afraid; be very afraid. (Part 2) 1.5M documented immigrants just kissed their healthcare goodbye, including domestic abuse & human trafficking victims.

🚨 CMS posts proposed #NBPP2027. Be afraid; be very afraid (Part 2 of 3)

1.5M documented immigrants just kissed their healthcare goodbye, including domestic abuse & human trafficking victims.

open.substack.com/pub/charlesg...

CMS posts Proposed NBPP 2027. Be afraid; be very afraid. (Part 2) IMPORTANT: You have until March 13th to SUBMIT A PUBLIC COMMENT to CMS about any of the proposed changes listed below! It may not make any difference but believe it or not sometimes it does, even unde...

🚨 CMS posts proposed #NBPP2027. Be afraid; be vary afraid (Part 2 of 3)

📣 IMPORTANT: You have until March 13th to submit a comment to CMS about any of these changes!

acasignups.net/26/02/16/cms...

. Catastrophic Plan Cost-Sharing Requirements Lastly, to best preserve a meaningful difference between the AVs of bronze and catastrophic plans, we propose to amend § 156.155(a)(3) to require catastrophic plans to provide no benefits for any plan year (except as provided in § 156.155(a)(4), (b), and (c)) until an amount equal to 130 percent of the maximum annual limitation on cost sharing, rounded down to the next lowest multiple of 50 dollars, is reached.

Substantially lower AV #Catastrophic plans are proposed for the #ACA in the #NBPP2027

P. 227 Under this proposal, issuers could apply the deductible that applies in the first year of coverage on an annual basis for each year within the coverage, or divide the annual deductible by 12, and apply it equally to each month of the policy throughout the entire term of coverage, similar to how a multi-year plan could choose to apply the annual limitation on cost sharing, as discussed in this section of the rule. For example, if the plan had an annual deductible of $6,000, it could apply 1/12 of that deductible monthly ($500 per month). We seek comment on if, and the degree to which, a plan could modify the amount of the annual deductible for each year of the multi-year policy.

P. 227 with monthly limits on cost sharing as an option is creating a massive adverse selection engine especially near OEP in #Catastrophic Plans in #NBPP2027 #ACA

I am glad I am not an actuary

Language from p. 226 of the NBPP 2027 Individuals dropping coverage under a multi-year catastrophic plan, either at the end of the term or mid-term, would be treated the same as individuals dropping coverage under a 1year policy either at the end of the year or mid-year, respectively, with respect to open enrollment and special enrollment periods

#Catastrophic plans in the #ACA with multiple year terms but annual opt-outs creates some really fascinating (and weird) game theory for enrollees and insurers. Let's minimize game theory

#NBPP2027

#NBPP2027 is out and P. 221 with 10 year Catastrophic plans Is INTERESTING

I see the health econ justifications as a variance and thus cost reducer, but also a mega pool splitting mechanism with annual opt-outs effectively

public-inspection.federalregister.gov/2026-02769.pdf