FAH submitted comments today regarding the Notice of Benefit and Payment Parameters for 2026 proposed rule for the Affordable Care Act (ACA) Exchanges. 

Key comments highlighted:

• FAH supports the work of Navigators and other assisters in helping consumers access health care coverage, yet we are concerned about expanding their role to refer consumers to programs designed to reduce medical debt. The FAH asserted that HHS does not have the authority to implement this expanded role, which would distract from the critical role these assisters play at the time of enrollment, i.e., to improve consumers’ access to affordable care and reduce the risk of medical debt through adequate and appropriate coverage. 

• In light of the Supreme Court decision in Loper Bright Enterprises v. Raimondo, which overturned Chevron deference to Administrative agency interpretations, the FAH urges HHS to amend, consistent with the ACA statute, the Exchange 90-day grace period regulations for non-payment of premiums before discontinuing coverage, such that insurers would pay all appropriate claims during the entire 90-day grace period, rather than putting providers to be at risk for non-payment during the last 60 days.

Read the comment letter here.