Comment Letter on Proposed Notice of Benefit and Payment Parameters for 2026

On October 4, 2024, the U.S. Department of Health & Human Services released its draft "Notice of Benefit and Payment Parameters" for plan year 2026. The proposed rule includes numerous provisions designed to enhance program integrity, support consumer decision-making, and improve consumers' experiences enrolling in and maintaining affordable insurance coverage. This comment letter provides legal and policy analysis of the proposals, including options for modifying the premium payment threshold proposal and potential language for codifying "silver loading."