The proposed Notice of Benefit and Payment Parameters (NBPP) for plan year 2027 introduces several policy changes that could affect how ACA marketplace issuers approach plan design, enrollment operations and certification strategy. 

This year’s NBPP was also released later than usual, creating a compressed timeline for health plans evaluating operational and strategic impacts ahead of the next filing cycle.  

While the proposed rule contains dozens of policy updates, several stand out for their potential operational and strategic implications for ACA health plans. Here are five of the most significant proposals health plans should be tracking as they evaluate readiness for the 2027 plan year. 

1. Removal of Standardized Plan Design Requirements 

One of the most significant proposals in the 2027 NBPP is the potential elimination of standardized plan design requirements in the ACA marketplaces. 

Standardized plans were originally introduced to simplify comparison shopping by aligning cost-sharing structures across issuers. Under the proposed rule, CMS would remove the requirement that issuers offer standardized options and eliminate limits on the number of non-standardized plans that can be offered. 

If finalized, this change would give issuers greater flexibility when designing marketplace products. Health plans could revisit plan structures, cost-sharing configurations and portfolio strategies without needing to meet standardized templates. 

However, greater flexibility does not automatically translate into better portfolio performance. Standardized plans often serve as anchor products that simplify comparison shopping and may perform well in certain markets. 

For many issuers, the bigger opportunity may be thoughtfully evaluating plan strategy rather than rushing to redesign portfolios. 

Recommendations for Health Plans 

• Model portfolio scenarios before redesigning products. Run actuarial and enrollment modeling on both standardized and non-standardized plan mixes to understand potential risk pool and member selection impacts before making structural changes. 

• Maintain internal plan design guardrails. Even if standardized plans are no longer required, establish internal templates or guardrails to prevent excessive product variation that complicates filing review and member decision-making. 

• Review HIOS ID strategy early. If portfolio expansion becomes viable, ensure plan ID reuse or reactivation will not create crosswalk, mapping or regulatory validation issues during the QHP filing process. 

2. Proposed Catastrophic Plan Changes 

The proposed rule also introduces significant changes to catastrophic plans beginning in plan year 2027. 

Among the proposed updates: 

• A substantial increase in the catastrophic plan maximum out-of-pocket (MOOP) threshold 

• Potential multi-year enrollment concepts for catastrophic products 

• Expanded eligibility or structural changes designed to increase catastrophic plan participation 

Catastrophic plans have historically represented a small portion of marketplace enrollment. But these changes could alter how issuers think about catastrophic offerings as part of their broader product strategy. 

Higher MOOP thresholds could significantly increase catastrophic plan cost exposure, affecting both pricing assumptions and consumer decision-making. 

At the same time, proposals related to longer-term enrollment introduce uncertainty around how these products would interact with the ACA’s annual rate setting and filing cycle. 

Until more details emerge in final rulemaking, catastrophic plans remain an area where strategic modeling may be more appropriate than immediate product changes. 

Recommendations for Health Plans 

• Update actuarial models for higher catastrophic MOOP levels. Assess how proposed MOOP increases could affect pricing assumptions, enrollment behavior and catastrophic plan viability within the portfolio. 

• Evaluate catastrophic plans as a strategic product segment. Determine whether catastrophic plans could attract new member segments or improve overall risk balance within the marketplace portfolio. 

• Model catastrophic plan scenarios across multiple future NBPP cycles. Because ACA marketplace rules are updated annually, catastrophic plan strategies that assume multi-year enrollment stability may need to account for policy changes in future NBPP rulemaking. 

3. Expanded SEP Verification Requirements 

Another proposal in the 2027 NBPP focuses on expanded verification requirements for Special Enrollment Period (SEP) enrollments on the federal marketplace. 

Under the proposal: 

• Exchanges would be required to verify at least 75% of SEP enrollments 

• Additional SEP categories could become subject to pre-enrollment verification 

• Documentation requirements may expand for certain income scenarios, including cases where reported income falls below 100% of the federal poverty level 

SEP verification policies have long been an area of focus for CMS due to concerns about improper enrollments and risk pool impacts. 

Expanded verification requirements could strengthen program integrity but may also introduce additional operational complexity for both health plans and exchanges. 

More verification steps can create friction during the enrollment process, particularly if documentation review, pend workflows or eligibility determinations require additional coordination between exchanges and issuers. 

As SEP verification expands, operational readiness will become increasingly important for both enrollment experience and compliance oversight. 

Recommendations for Health Plans 

• Audit SEP verification workflows now. Review how current enrollment systems handle documentation, pend statuses and eligibility verification to identify potential operational bottlenecks. 

• Prepare member communication protocols for documentation requests. Expanded verification requirements may increase documentation outreach during SEP periods, making clear member instructions and call center readiness essential. 

• Strengthen enrollment audit documentation. Ensure policies, procedures and verification practices are clearly documented in case expanded verification requirements lead to increased regulatory oversight. 

4. Increased State Authority in Marketplace Oversight 

The rule also includes provisions that would increase state authority in reviewing marketplace plan requirements. Under the proposal, states with an effective review program could assume responsibility for certain oversight functions currently performed by CMS, including network adequacy (more on that in the next update) and Essential Community Provider (ECP) review. 

CMS would defer to state standards for these areas, although certain submission data would still flow through federal systems such as HIOS. 

The proposal also includes changes that would allow states to transition directly from a federally facilitated exchange (FFE) to a state-based exchange (SBE) without first operating under a hybrid SBM-FP model. 

These changes signal a continued shift toward greater state flexibility in marketplace governance. While that flexibility may allow states to tailor oversight to local market conditions, it could also increase variation across states in how marketplace rules are applied. 

For issuers operating in multiple states, this could introduce additional complexity in filing strategy, compliance monitoring and regulatory coordination. 

Recommendations for Health Plans 

• Map regulatory responsibilities by state. Identify which operating states may pursue expanded oversight authority and determine how that could affect filing timelines, documentation requirements and regulatory coordination. 

• Build internal monitoring for state marketplace policy changes. State-driven oversight may introduce faster-moving regulatory updates that require closer monitoring throughout the filing cycle. 

• Align product and compliance teams on state-level differences. Multi-state issuers should prepare for variations in network adequacy review, ECP expectations and certification standards. 

5. Network Adequacy Review Changes 

The proposed rule introduces changes to network adequacy review standards, allowing certain states to conduct their own network availability reviews rather than relying solely on CMS’s federal review framework. 

Network adequacy has traditionally been one of the most complex aspects of marketplace certification. Building provider networks, documenting access standards and passing network review often requires significant preparation well before filing season. 

Allowing states to take on more responsibility for network adequacy review could: 

• Reduce reliance on the federal network review framework 

• Introduce new state-specific review standards or documentation requirements 

• Lower certain barriers to marketplace entry in states that adjust network standards 

However, it may also require issuers to adapt to different review processes depending on the state. 

Recommendations for Health Plans 

• Confirm which review authority will apply in each state. Determine whether network adequacy review will be conducted by CMS or state regulators for the 2027 certification cycle. 

• Prepare for potential changes in documentation requirements. State-led reviews may introduce new network submission formats, provider access standards or validation processes. 

• Reassess network build timelines if review standards shift. If network adequacy thresholds change, issuers may need to adjust contracting strategies and provider outreach earlier in the filing cycle. 

Preparing ACA Issuers for Plan Year 2027 

Although the 2027 NBPP is still in the proposed stage, the direction of the rule highlights several themes for ACA issuers: greater flexibility in plan design, expanded operational oversight in enrollment, more state-driven marketplace governance, and shifts in product and network strategy. 

For health plans, preparing for these changes means evaluating potential impacts across multiple internal teams, including regulatory, product, actuarial, enrollment operations and compliance. 

Even before the rule is finalized, organizations may benefit from identifying which proposals require early planning, modeling or operational adjustments ahead of the next filing cycle. 

As the final NBPP develops, health plans that approach these proposals strategically—rather than reacting late in the filing process—will be better positioned to navigate the evolving marketplace landscape.