Families USA’s Comments On Notice Of Benefit And Payment Parameters For 2025 Skip to Main Content

Families USA’s Comments On Notice Of Benefit And Payment Parameters For 2025


The “notice of benefit and payment parameters” is a federal rule, issued annually, that updates parameters for health plans operating in the federal and state marketplaces, and can make changes in the enrollment process for marketplace plans. Families USA commented on the following issues for the Notice of Benefit and Payment Parameters for 2025 proposed rule:

  • Dental coverage – Families USA applauds the option for states to cover adult dental services as an essential health benefit, and we urge CMS to add adult dental benefits as a required category of coverage.
  • Network adequacy – Families USA supports national improvements in network adequacy standards for marketplace plans. We further recommend national minimum standards regarding wait time for appointments, and particularly want to assure adequate access to substance use treatment as well as mental health services.
  • Clearly identifying assisters, navigators, and Medicaid pathways in all states – this has not been fully operationalized everywhere, and can particularly be a problem as states transition from the federal platform to a state exchange.
  • Need to clamp down on web brokers and direct enrollment entities that ask for inappropriate information – these websites should not be asking consumers who may want to buy marketplace plans about their health conditions. The explanation that people may be able to find other qualified health plans by visiting their marketplace website should be prominent and easy to read.

Click the download button below to view the Comment Letter.