By Sabrina Corlette and Jason Levitis

On January 13, 2025, the Centers for Medicare & Medicaid Services (CMS) released its final Notice of Benefit & Payment Parameters (NBPP) for plan year 2026. This annual regulation, referred to informally as the “Payment Rule” or “Payment Notice,” prescribes standards and rules that govern insurers and health insurance Marketplaces under the Patient Protection & Affordable Care Act (ACA). The regulation, the last Payment Rule issued by the Biden administration, went into effect on January 15, 2025.

In addition to the final Payment Notice, CMS released a fact sheet and a final 2026 Letter to Issuers.

The 2026 Payment Notice represents a final set of Marketplace and health insurance policies from the Biden administration. The administration describes its goals with these policies as providing “quality, affordable coverage” to consumers while minimizing administrative burden and advancing health equity.

In this Forefront article, we focus on policies related to Marketplaces, insurance reforms, and Advance Premium Tax Credits (APTC). An article by Matthew Fiedler will review CMS’ changes to the ACA’s risk adjustment program.

Reducing Fraudulent Enrollments And Improving Program Integrity

In 2024, the federally facilitated marketplace (FFM) confronted a significant increase in enrollments and plan changes made without consumers’ knowledge or consent, driven by unscrupulous health insurance brokers seeking to profit from commissions. These unauthorized enrollments have caused significant harm, resulting in consumers enrolled in plans they didn’t sign up for, moved to plans with higher cost-sharing, and at risk for unexpected tax liabilities when they file their 2024 tax return. In response, CMS has made a number of programmatic and policy changes, addressing security lapses in the system and verifying consumer consent when a new broker is listed on an account.

In its draft 2026 Payment Notice, CMS proposed amending their oversight authority to better respond to cases of unauthorized enrollment or plan switching, and to hold brokers, agents, and web-brokers (collectively “brokers”) accountable for wrongdoing. In its final rule, CMS has adopted these changes as proposed. Specifically, the changes clarify CMS’ authority to (1) pursue enforcement actions against both the individual broker or agent committing fraud and the owners or executives in a leadership position at the agency where that broker or agent works (referred to as “lead agents”), and (2) suspend a broker or agency’s ability to conduct transactions with the health insurance Marketplace when CMS identifies an “unacceptable risk.” However, such a system suspension does not terminate the broker’s contract with the Marketplace; brokers who are suspended may continue to enroll consumers using the Marketplace call center or by having the consumer included in the transaction (referred to as the “side-by-side” pathway).

CMS particularly sought comments from state insurance regulators on this proposal, asking for input on how best to define “lead agent.” After reviewing that input, CMS has finalized a definition of lead agent to include persons who register and/or maintain a business with a state and/or any person who registers as a business with the Marketplaces.

Many commenters supported the proposed clarifications to CMS’ authority, noting that the changes would help protect consumers. However, one commenter noted that taking action against “lead agents” could have negative consequences for downline brokers who have not committed fraud. While CMS acknowledges this potential, it argues that the ability to go after lead agents is necessary to protect consumers and the integrity of the Marketplaces.

Some commenters expressed concerns that the data CMS’ uses to identify brokers committing fraud could have an adverse impact on minority groups and minority brokers. CMS responded by noting that their data have shown that minority or disadvantaged groups are more likely to be targeted by brokers who commit fraud. For example, CMS noted that such brokers may target a population that does not speak English as a first language and use the language barrier to their advantage. This can result in system suspensions against brokers who work with these groups. CMS notes that brokers should be able to quickly resolve a system suspension by providing documentation of consent or explaining the steps they’re taking to address the risks identified by CMS.

Some commenters recommended that CMS report system suspensions to state insurance departments, Marketplace insurers, and the public, and require suspended brokers to disclose their status to clients. CMS declined to adopt these recommendations, noting that their current regulatory framework does not allow them to share information about system suspensions. The agency also disagreed that brokers should be required to disclose their suspension to consumers, stating that it could “confuse consumers.”

Other commenters argued that suspended brokers should also not be allowed to use the system of a state-based Marketplace (SBM). CMS declined to adopt this recommendation, instead encouraging SBMs that operate a direct enrollment program to adopt a system suspension enforcement framework of their own.

CMS is also finalizing updates to the Model Consent Notices that brokers use to document consumers’ consent. The new model notices will include a section where the broker can document a consumer’s confirmation of the accuracy of the information being submitted on their behalf. CMS will also be providing brokers with scripts that they can use when obtaining consent via an audio recording. Commenters generally supported these updates, noting they would provide brokers with more clarity on how to ensure compliance.

Clarifying Timelines For Resolving Enrollment Data Corrections

CMS finalizes its proposal to codify guidance clarifying the timeline for state Marketplaces to adjudicate and report enrollment corrections to CMS. Under August 2024 guidance, state Marketplaces have 60 days from when they receive a complete report of the inaccuracy from an insurer to assess and resolve the case and report any correction to CMS. Enrollment reporting by Marketplaces to CMS is the basis for payment of advanceable PTCs to insurers, so accurate and up-to-date data is important for program integrity and effective operations. In response to some commenters’ concerns that the deadline would require state-based Marketplaces to adjudicate cases before they have received all needed information, the final rule emphasizes that the 60-day timeline begins only when the insurer has provided “all the information that the State Exchange requires or requests to properly assess the inaccuracy.”

Publishing State Marketplace Operational Reporting

CMS finalizes in modified form its proposal to release information collected from state Marketplaces about their operations and performance. The proposed regulations called for state Marketplaces to publicly release information provided to CMS using the State Marketplace Annual Reporting Tool (SMART), as well as key performance metrics like website and call center traffic. CMS uses this information to identify risks, provide technical assistance and corrective actions, and inform policy development.

Comments to the proposal generally supported the goal of increasing transparency. But state Marketplaces expressed concerns that the SMART reports include sensitive information about measures to support program integrity and combat fraud, such as procedures to verify consumer information. Releasing this information could provide a roadmap for evading program integrity tools. State Marketplaces also noted that removing this information from the SMART would diminish its value as an oversight tool.

In response to these concerns, CMS has decided not to release the SMART reporting but instead to focus on releasing a wider range of metrics about Marketplace operations and performance. At a minimum, CMS will publish the following data elements that it currently collects from State Exchanges:

• Expenditures on consumer marketing, education, and outreach
• Expenditures on the Navigator program
• Call center metrics, including, calls received, average wait time, call terminations while waiting, and average call duration
• Exchange website metrics, including website and mobile application visits and unique visitors

Supporting Consumer Decision-Making And Improved Plan Choices

CMS is finalizing changes to standardized plans on the FFM and making adjustments to the limits on non-standardized plans, in order to help consumers make informed plan choices. The agency has also clarified its authority to decline to certify plans for Marketplace participation and will be moving forward with increased oversight of essential community provider standards and the publication of plans’ quality improvement strategies.

Standardized Benefit Designs

CMS has made only modest changes to the standardized plans that insurers in the FFM and state-based Marketplaces that use the federal platform (SBM-FPs) must offer in 2026. Since the agency unveiled standardized plan options in 2023 to support consumers’ plan comparisons, it has made only small adjustments to the plan designs, so that they can continue to have an actuarial value within the permissible de minimis range for each metal level (bronze, silver, gold, and platinum).

However, for plan year 2026, CMS will require insurers that offer multiple standardized plans within the same product network type, metal level, and service area to ensure that there is a “meaningful difference” among these plans in terms of benefits, provider networks, and/or formularies. The agency has observed that several insurers have been offering “indistinguishable” standardized plan options, resulting in the unnecessary proliferation of plans and increased consumer confusion.

In CMS’ draft 2026 Payment Notice, the agency proposed that an insurers’ standardized plans would be considered meaningfully different if they had different covered benefits, provider networks, and/or formularies. In finalizing this requirement, CMS has slightly modified the standard so that instead of calling for a “difference in formularies,” it instead calls for a “difference in included prescription drugs.” The agency made this modification to ensure that minor differences in prescription drug cost-sharing, which would be reflected by differences in formulary IDs, would not constitute a meaningful difference.

CMS received many comments supporting the requirement that insurers offer standardized plans, noting that they help consumers draw meaningful comparisons between plan options. However, a few commenters argued that standardized plans reduce consumers choices. In response, CMS noted that insurers can continue to offer non-standardized plans in the FFM and SBM-FPs that allow them to offer innovative plan designs and meet consumers’ needs.

Some commenters also encouraged CMS to design standardized plans that further limit the use of coinsurance and provide pre-deductible coverage for essential health care services. CMS generally agreed that coinsurance and deductibles can increase consumer uncertainty about how much health care services will cost them, but the agency noted that the actuarial value constraints of the prescribed metal levels prevent the agency from significantly expanding pre-deductible coverage or reducing the use of coinsurance.

Many commenters also supported adopting the meaningful difference standard, noting their appreciation for CMS’ efforts to reduce duplicative plan offerings. CMS generally agreed with these comments and noted that if it finds that insurers are attempting to circumvent the standard, or that the standard is not strict enough, it will consider tightening the standard in future rulemaking.

Limits On Non-Standardized Plan Options

In 2024, CMS required insurers to limit the number of non-standardized plans they offered in the FFM and SBM-FPs to four plans in each the following four categories:

• product network type;
• metal level;
• inclusion of dental and/or vision benefits; and
• service area

For 2025 and subsequent years, the limit was reduced to two plans per category. At the same time, CMS created an exceptions process, allowing insurers in the FFM and SBM-FP to offer more than two non-standardized plan options per category if they could demonstrate that the additional plans had specific design features that would “substantially benefit consumers with chronic and high-cost conditions.” Under the non-standardized plan limits, if an insurer wanted to offer the maximum number of non-standardized plans, and offered plans with two network types (like HMO and PPO), they could theoretically offer a maximum of 32 plans in a given metal level and service area.

However, in its 2026 draft Payment Notice, CMS noted that in establishing these limits, it “failed to properly distinguish” between adult and pediatric dental benefits. Therefore, it proposed, and now finalizes, an amendment to its rules such that insurers are limited to offering two non-standard plan options per product network type, metal level, and inclusion of adult dental coverage, pediatric dental benefit coverage, and adult vision benefit coverage, in any service area.

Several commenters supported this change, and many others expressed general support for limiting the number of non-standardized plans that insurers can offer. These commenters observed that consumers have in recent years been confronted with too many plan choices, resulting in “choice overload” that can lead to suboptimal plan selections. However, several commenters objected to creating a distinction between pediatric and adult dental coverage, arguing that doing so would undermine the goal of reducing plan proliferation and increase consumer confusion. CMS disagreed, concluding that the inclusion of dental and vision benefit coverage represents “meaningful coverage variations.”

Some commenters argued that CMS should allow for more state flexibility, noting that not all states have the same excess of plan options. CMS responded that the operational cost and burden of tailoring the HealthCare.gov platform to different state needs outweighs the potential benefits of state flexibility.

Certification Standards For Marketplace Health Plans

Under the ACA, the Marketplaces have authority to certify health plans for participation (referred to as a “qualified health plan” or QHP) if the plan meets certification requirements and if the Marketplace determines that the plan’s inclusion is “in the interests of” consumers. In its proposed rule, CMS noted that although the ACA makes clear that this means Marketplaces have authority to deny certification to a plan, that authority is not explicit in implementing regulations. CMS therefore proposed, and is finalizing, an amendment to those regulations specifying that the Marketplaces may deny certification of any plan that does not meet the certification criteria or whose inclusion would not be in the interests of Marketplace enrollees. Most commenters supported this proposal.

CMS is also finalizing a revision to the process for insurers to request reconsideration if their certification is denied. As finalized, an insurer seeking reconsideration would have the burden of providing “clear and convincing” evidence that CMS’ determination to deny certification was in error. Most commentators agreed with this provision of the proposed rule.

Reducing The Risk Of Insurer Insolvency

In its proposed rule, CMS sought comment on how the agency could better coordinate with state insurance departments and the National Association of Insurance Commissioners (NAIC) to identify and respond to the risk that a Marketplace insurer could become insolvent. The agency will take these comments into consideration as it develops future rulemaking.

Federal Review Of Compliance With Essential Community Provider Standards

The ACA requires Marketplace health plans to include in their networks “essential community providers” (ECPs) that serve predominantly low-income, medically underserved individuals. Due to inadequacies with CMS’s information technology (IT) systems, the agency has had to rely on states that conduct Marketplace plan management functions to perform oversight of insurers to ensure that they are meeting the ECP standards. In its proposed 2026 Payment Notice, CMS noted that it has recently improved its IT systems, and can now collect the necessary ECP data from insurers. Therefore, the agency proposed to conduct its own evaluations of insurers’ networks to assess compliance with ECP requirements.

CMS is finalizing this policy as proposed. Many commenters supported greater CMS review of plans’ inclusion of ECPs in their networks, noting that the proposal would allow for more consistency across plans and improve consumer access to ECPs. A few commenters suggested that CMS does not have the authority to conduct these reviews, but CMS responded that the ACA allocates to the FFM clear responsibility to conduct the reviews necessary to determine whether an insurer has met the QHP certification criteria.

Publicizing Insurers’ Quality Improvement Strategies

CMS is also finalizing a proposal to publish aggregated, summary-level information about Marketplace insurers’ quality improvement strategies (QIS). Under the ACA, Marketplace health plans are required to implement a QIS that aims to improve health outcomes, reduce hospital readmissions, improve patient safety, reduce medical errors, promote wellness, and reduce health disparities. Many commenters supported publishing insurers’ QIS information, noting that it advances CMS’s goals of promoting transparency and learning from best practices for quality improvement.

Efforts To Improve Consumers’ Experiences Obtaining And Maintaining Affordable Coverage

The 2026 Payment Notice finalizes several proposals designed to ease administrative burdens, improve communications with consumers, and help ensure coverage affordability.

Flexibility On Premium Payment Thresholds

CMS finalizes with some modifications its proposal to give insurers additional options to avoid terminating coverage when enrollees under-pay premiums by a de minimis amount. The modifications provide some additional flexibility, though less than some commenters requested.

The ACA generally requires payment of the full premium to effectuate enrollment (referred to as a “binder payment”) or avoid triggering a three-month grace period or termination. Long-standing regulations permit insurers to set a minimum percentage of the consumer’s premium share that they will accept for these purposes (a “net premium percentage threshold”). For example, if a consumer’s full premium is $400, of which APTC covers $300, and the issuer permits a net premium threshold of 95 percent, and then the consumer satisfies the threshold so long as they pay at least $95 (95 percent of the $100 net premium).

This threshold provides relief where a consumer makes a nearly complete payment. But it doesn’t help if the consumer owes only a minimal amount and pays a smaller share. For example, if the premium was $400, APTC was $398, and the consumer paid none (or even $1.50) of their $2 share, a net premium threshold of 95% would not protect the consumer, since they would not have paid 95 percent of their $2 net premium.

To address such situations, the proposed regulations offered two additional threshold options. First, insurers could set a threshold of no less than 99 percent for the combined premium paid by APTC and the consumer (a “gross premium percentage threshold”). Second, insurers could set a dollar value for permissible non-payment (a “fixed-dollar threshold”), which must be no more than $5. CMS also proposed to clarify that, for the existing threshold option, a threshold of at least 95 percent of the net premium would be considered reasonable.

The proposed rule included some tight constraints on the new options. Both would apply for purposes of triggering grace periods and coverage loss, but not for binder payments. And insurers could choose only one of the three threshold options. Furthermore, all of the options would be based on the accumulated non-payment. For example, if the insurer has a dollar-value threshold of $5 and a consumer underpays by $3 for two consecutive months, the threshold would offer no protection in the second month, since the total shortfall of $6 exceeds the $5 threshold.

Commenters were generally supportive of the new options while suggesting greater flexibility. Commenters noted that, under the constraints described above, if an insurer used either of the new options, consumers that very slightly underpaid a binder payment could not have coverage effectuated. Commenters also questioned why the new options wouldn’t apply to binder payments, requested broader boundaries for the options, and suggested that the new options disregard accumulated non-payments.

In the final rule, CMS provides additional flexibility, though less than some commenters suggested. First, CMS expands the range of permissible thresholds for both new options: gross premium percentage thresholds must be at least 98 percent (instead of 99 percent), and the fixed-dollar thresholds must be no more than $10 (instead of $5). The final rule also permits insurers to offer both a fixed-dollar threshold and either one of the percentage-based thresholds. As a result, an insurer that provides both a net premium percentage threshold and a fixed-dollar threshold could offer relief both with respect to binder payments and to consumers who pay a smaller amount of minimal premium. But CMS does not extend the new threshold options to binder payments, which denies relief to consumers who pay a smaller amount of a minimal binder payment. CMS also still requires the consideration of accumulated shortfalls.

On a related note, the Treasury Department and the IRS recently finalized regulations under the premium tax credit (PTC), clarifying that a consumer who pays less than the full premium may still be eligible for PTC so long as they maintain coverage, including pursuant to a permissible premium payment threshold. This addresses potential situations where a consumer who is unable to pay a small share of the premium may be deemed ineligible for PTC and therefore owe back substantial APTC at reconciliation.

Leveraging Consumer Assisters To Connect Consumers With Medical Debt Relief

Millions of Americans experience medical debt, including an estimated 33 percent of people enrolled in Marketplace health plans. The burden of medical debt falls disproportionately on vulnerable and underserved individuals, including young adults, women, those with low incomes, and Black and Hispanic families.

Hospitals and health systems are the primary sources of medical debt. Many of these entities have staff who serve as Certified Application Counselors or non-Navigator consumer assisters to help people enroll in Marketplace coverage. CMS sought comment on whether these assister personnel could, within the bounds of the ACA, be asked to refer consumers to programs designed to reduce medical debt. The agency notes that it will take these comments into account in future rulemaking.

Cost-Sharing Reduction (CSR) Loading

CMS adopts regulatory language codifying its long-standing policy deferring to state insurance regulators on how premiums account for cost-sharing reductions (CSRs) in the absence of federal CSR payments. The ACA’s CSR rules require insurers to reduce cost-sharing in silver plans for certain eligible individuals. The ACA envisions CMS reimbursing insurers for the cost of CSRs, but in 2017 the Department of Justice determined that there was not a valid appropriation for these payments, and CMS halted them. To satisfy the requirements for actuarially justified rates, CMS then permitted states—beginning with plan year 2018—to instruct insurers to increase premiums to account for the cost of CSRs, generally by “loading” the cost onto silver plans, so long as these adjustments are reasonable and actuarially justified.

CMS has repeatedly affirmed that this “silver loading” or “CSR loading” is permissible without codifying it in regulations. In the proposed rule, CMS once again affirmed this position and requested comments on codifying the rule, noting it continues to receive questions about permissible CSR loading practices. Commenters generally supported the proposal, and CMS now codifies that CSR loading is permissible “if permitted by the applicable State authority.” A few commenters expressed concern that CMS’s regulatory language might depart from its traditional deference to states on how to account for unpaid CSRs in an actuarially justified manner. The final rule emphasizes that the codified language does not change its deference to states and is not expected to change state practices.

Further Clarity On FTR Notices

CMS finalizes language clarifying Marketplaces’ options for notifying enrollees about potential eligibility loss due to failure to comply with the requirement that APTC recipients file a tax return and reconcile their APTC, a set of rules known as “failure to reconcile,” or FTR. The proposed rule clarified that Marketplaces have two options for notifying consumers who have failed to file and reconcile for two years and whose APTC eligibility is thus in immediate jeopardy: through a direct notice to the tax filer clearly indicating FTR status (if they can do so in keeping with tax privacy rules), or through a more general notice that explains FTR rules and warns of potential APTC loss without specifying the reason. These are the same options that Marketplaces have with respect to consumers who have failed to file and reconcile for one year.

Comments were generally supportive, and CMS finalizes the proposed language without change. The federal notices, which SBMs may use as a model, are posted on the CMS website.

Easing The Appeals Process

Under previous CMS rules, family members or authorized representatives could apply for coverage on behalf of an individual, but they could not seek an appeal of an eligibility determination on that person’s behalf without going through extra administrative steps. In this final 2026 Payment Notice, CMS has amended its regulations, finalizing language in the proposed rule allowing application filers to submit appeal requests on behalf of applicants and enrollees, for both FFM and SBMs.

Most commenters supported this proposal, noting that it would reduce the burden on applicants while bringing more consistency to the process. One commenter suggested that CMS allow brokers to file appeals on behalf of consumers, but CMS declined, noting that doing so would run counter to its recent efforts to combat misconduct and fraud among Marketplace brokers.

Other Proposals

The 2026 Payment Notice also establishes a contingent user fee policy in light of the potential expiration of the enhanced PTCs in 2026, provides more time to access and use the Actuarial Value Calculator, and clarifies CMS’ payment methodology under the ACA’s Basic Health Program.

User Fee Uncertainty

CMS finalizes its proposal to increase the user fees for Marketplaces on the federal platform, in large part to account for lower enrollment that is expected if Marketplace subsidy enhancements expire after 2025. PTC enhancements were enacted in the American Rescue Plan Act of 2021 and extended in the Inflation Reduction Act of 2022. The enhancements are now scheduled to expire at end of the 2025, but there are efforts underway to extend them. Expiration of the enhancements is widely expected to substantially reduce enrollment, which in turn would require higher a higher user fee to provide sufficient revenue to support federal platform operations.

If the enhancements expire as scheduled, the FFM user fee would increase from 1.5 percent in 2025 to 2.5 percent in 2026, and the SBM-FP user fee would increase from 1.2 in 2025 percent to 2.0 percent in 2026. CMS also finalizes a lower set of user fee rates that would take effect if subsidy enhancements are extended by July 31, 2025. If Congress acts by July 31, 2025 to extend the enhancements through 2026, the 2026 user fees would be 2.2 percent in the FFM and 1.8 in the SBM-FP. These figures are generally consistent with those outlined in the proposed rule, though CMS had then suggested a deadline of March 31, 2025.

User fees are paid by Marketplace insurers to support the operations of the FFM and federal platform. The fee is calculated as a percentage of Marketplace premiums collected. The fee supports Marketplace activities that benefit insurers on the federal platform, including eligibility and enrollment processes; outreach and education; managing navigators, agents, and brokers; consumer assistance tools; and certification and oversight of Marketplace plans.

Streamlining The Release Of The Actuarial Value Calculator

The actuarial value (AV) calculator, published by CMS each year, is used by health insurers to determine whether their health plans meet the prescribed metal level of coverage (bronze, silver, gold, and platinum). Since 2015, CMS has initially released a draft version of the AV calculator, solicited comments on it, and then released a final version.

In its proposed rule, CMS noted that users have provided feedback that they would prefer the AV calculator to be released earlier in the year, to allow insurers to prepare for state filing deadlines. In response to this feedback, CMS proposed, and is finalizing, a process by which the agency will release only a single, final version of the AV calculator for the next plan year. The public will still be given an opportunity to comment on it, but any feedback will be incorporated into the development of the AV calculator for the following year. This change will allow CMS to release the AV calculator earlier in the year.

Many commenters supported this proposal, with state commenters noting that it would help them finalize their state-specific standardized benefit designs. Others applauded the reduced administrative burden for insurers. Those interested in commenting on the AV calculator may do so via email at PMPolicy@cms.hhs.gov.

BHP Payment Methodology Clarifications

CMS finalizes two proposals to clarify the payment rules that apply in some rare situations under the Basic Health Program (BHP).

The ACA gives states the option to establish a BHP to cover relatively low-income residents (those with incomes up to 200 percent of FPL) who would otherwise be eligible for the PTC. States have flexibility over BHP design so long as it is generally no less generous or affordable than Marketplace coverage at the same income level. BHP coverage is funded through federal payments to the state that are generally equal to 95 percent of the PTC enrollees would have otherwise received.

The first change addresses situations where a state partially implements the BHP in the first year. A state can generally choose whether the BHP payment calculation is based on current-year or prior-year premiums. Because CSR loading is typically minimal in BHP states, the BHP payment regulations include an adjustment intended to capture the forgone impact of CSR loading on PTC. In a state transitioning to a BHP, this adjustment applies to the first BHP year if the payment is based on current-year premiums, but not if is based on prior year-incomes, since silver loading still had its full impact in that year.

While this rule generally avoids both underpayment and double-counting, it does not account for cases where a state partially implements the BHP in the first year and thus silver loading is only partially reduced. The proposed rule permitted the silver loading adjustment to be applied in part in such cases, and the final rule adopts the proposal without change. This rule appears aimed at Oregon, which is undergoing a phased transition to a BHP.

CMS also finalizes its proposal to clarify how the BHP methodology addresses cases where there are multiple benchmark silver premiums within a county. Codifying its long-standing practice, CMS proposes to clarify that, in such cases, the payment calculation uses the benchmark premium appliable to the largest fraction of county residents.

Authors’ Note

Sabrina Corlette and Jason Levitis received support for their time and work on this piece from the Robert Wood Johnson Foundation. The views expressed here do not necessarily reflect the views of the Foundation, the Urban Institute, or Georgetown University.

Sabrina Corlette and Jason Levitis “Final 2026 Notice of Benefit & Payment Parameters: Marketplace Standards And Insurance Reforms,” February 4, 2025, https://www.healthaffairs.org/content/forefront/final-2026-notice-benefit-payment-parameters-marketplace-standards-and-insurance. Copyright © 2025 Health Affairs by Project HOPE – The People-to-People Health Foundation, Inc.