As I explained, every year, the Centers for Medicare & Medicaid (CMS) puts together a bunch of proposed modifications to the implementation details of the ACA. Some are simple clarifications of existing procedures; some are minor tweaks; and some are major changes. Of the major changes, some are positive...and some are negative. In the case of the 2022 NBPP, there are examples of all three...and the major changes are really major. As in, ranging from harmful to likely flat-out illegal.
For 2022, there were several NBPP items which seem either innocuous or are actually good ideas...but there are a couple of pretty questionable ones and a few more which would be outright devastating (there are also a few involving things like Risk Adjustment which I'm not familiar enough with to comment on one way or the other).
UPDATE 12/31/20: The deadline to submit public comments has passed. In the end, there are 320 comments, 243 of which were submitted after I posted this entry. The wording on a random check of some finds that at least a couple dozen appear to have been guided by my own sample comment below, which I'm glad to see.
Now we'll just have to wait and see. Thank you to everyone who helped out!
Last month, I wrote about the annual Notice of Benefit & Payment Parameters for 2022 (NBPP) from the Centers for Medicare & Medicaid (CMS). This is a long, wonky document published each year which includes a bunch of proposed modifications to various aspects of how the ACA is administered and implemented.
Some of the proposed changes each year are pretty much mandatory. Some are completely up to whoever is running CMS/HHS at the time. Some are nominal tweaks; some are major changes.
