Unpacking The Final 2019 Payment Notice (Part 3)

The Centers for Medicare and Medicaid Services (CMS) finalized the Benefit and Payment Parameters rule for 2019 on April 9, 2018. The first post addressed the rule’s changes in plan benefits, eligibility, and enrollment changes. The second post discussed the general market reforms, rate review, the medical loss ratio, and the SHOP exchanges. This final post discusses the rule’s changes to the Affordable Care Act’s (ACA’s) risk adjustment program.

The ACA included three premium stabilization programs: risk corridors, reinsurance, and risk adjustment. The risk corridor and reinsurance programs lasted only for 2014, 2015, and 2016; they are now finished except for three dozen lawsuits that continue in the Court of Claims. These suits allege that the...