

The Centers for Medicare & Medicaid Services (CMS) has finalized a rule allowing non-network health plans to participate in Affordable Care Act marketplaces beginning in 2027 for state exchanges and 2028 for the federal marketplace. Unlike traditional insurance, these plans do not rely on provider networks, instead setting reimbursement rates for medical services directly, a model proponents say could lower premiums and expand consumer choice.
The rule's impact will largely depend on how state regulators choose to implement it. Spencer Perlman, Managing Partner and Director of Healthcare Research at Veda Partners, noted that states taking a more flexible approach may see greater adoption of non-network plans, while stricter oversight could limit savings and reduce their appeal. “If states are doing their job and ensuring that there’s some comparability between non-network and network plans, you’re probably not going to get the type of savings that you want. But if you allow them to undercut the market, then you might have success,” Perlman said.
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