Lexology April 3, 2024
On April 2, 2024, the Centers for Medicare & Medicaid Services (CMS) released the 2025 Notice of Benefit and Payment Parameters (NBPP) final rule (Final Rule), finalizing policies applicable to qualified health plans offered on health insurance exchanges as well as certain policies applicable to certain health plans more broadly. The Final Rule codifies in regulation CMS’s longstanding policy that all covered prescription drugs, including those beyond the minimum required to be covered under the Essential Health Benefits (EHBs) coverage requirement (but excluding such drugs required to be covered pursuant to a state mandate), are EHBs. This development has implications for both (1) the annual cost-sharing limit and (2) the prohibitions on lifetime and annual dollar limits established under the...
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