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AHIP Comments on Notice of Benefit and Payment Parameters for the Individual Market, 2023

Press Release

Published Jan 27, 2022 • by AHIP

Washington, D.C. – January 27, 2022 – Every American who buys their own coverage deserves a marketplace that provides them with many affordable, high-quality choices. With that priority front and center, AHIP today submitted comments in response to the Department of Health and Human Services (HHS) Notice of Benefit and Payment Parameters for 2023. Here are the highlights:

The Individual Market Is Stable and Growing

“The recent increase in enrollment through the marketplaces is a significant achievement toward ensuring that every American has the financial peace of mind that health insurance provides. More than 14.5 million Americans have enrolled in coverage through the marketplaces for plan year 2022, a number that is expected to grow once final data is available.”

“The American Rescue Plan Act made certain that more Americans have choices of coverage with a low or $0 premium, and many can receive more generous subsidies to lower their out-of-pocket costs. We applaud the Department’s efforts to get more Americans covered, especially through increased Navigator funding and targeted outreach and education for populations … traditionally uninsured or underinsured.”

“The continued stability and growth of the ACA marketplaces is also due in large part to policies that have promoted a stable regulatory environment, increased competition, and enabled issuers to offer innovative products that consumers want and need.”

The NBPP Includes Policies That Could Undermine That Stability

“We are concerned that some of the policies proposed in this Payment Notice may take large steps backward, undermining this hard-won stability and significantly limiting innovation and competition. Wherever possible, our comments offer workable alternative policy solutions that will achieve similar goals while minimizing disruption for everyone.”

A Desire to Work Together Toward Workable Solutions

“Given the broad and substantial set of proposals and significant challenges to fully assess the impact under the short comment time frame, we recommend providing … additional comment opportunities before finalization. … We are particularly concerned that finalizing many of these policies for the 2023 plan year would result in a significant change from current requirements and plan offerings, placing a significant strain on issuers and providers and be disruptive for consumers.”

About AHIP

AHIP is the national association whose members provide health care coverage, services, and solutions to hundreds of millions of Americans every day. We are committed to market-based solutions and public-private partnerships that make health care better and coverage more affordable and accessible for everyone. Visit to learn how working together, we are Guiding Greater Health.