PAN submits comments on 2027 NBPP proposed rule regarding patient cost and benefit protections

The PAN Foundation submitted comments on the Department of Health and Human Services’ (HHS) 2027 Notice of Benefit and Payment Parameters (NBPP) proposed rule.

Reducing the maximum out-of-pocket limit

For 2027, the annual limitation on cost-sharing for Affordable Care Act (ACA) plans is $12,000 for individuals, an amount that most patients simply do not have and is a significant increase from the 2026 limit of $10,600. The ACA’s annual maximum out-of-pocket limit is intended to provide financial protection to plan enrollees, however at a price point this high, it becomes meaningless for most Americans.

Copay accumulator policy

PAN remains disappointed that the proposed rule does not revise policies related to copay assistance and a patient’s deductible. We urge the Centers for Medicare and Medicaid Services (CMS) to allow copay assistance to be counted toward a patient’s deductible to enable patients to access needed treatments without financial hardship.

Allow states to add routine adult dental benefits as Essential Health Benefits (EHBs)

PAN opposes CMS’s proposal to reverse course and reinstate a prohibition on states to include routine adult dental services as an essential health benefit. Oral health plays a vital role in enhancing overall health outcomes and improving patients’ quality of life. States should be allowed the option to add routine adult dental services as an EHB by updating their EHB benchmark plans and would align these plans more closely with the private marketplace. Given the expanding dental benefit offerings in employer-based plans, it is essential that the scope of EHBs be extended to Americans obtaining Marketplace coverage.

Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters
for 2027; and Basic Health Program [CMS-9883-P] RIN 0938-AV62