The Centers for Medicare & Medicaid Services (CMS or the agency) kicked off a flurry of springtime regulatory activity for health insurance issuers with publication of the final Notice of Benefit and Payment Parameters for 2015 (Final Notice). The new requirements are primarily relevant for entities participating in the individual and small group health insurance markets, whether on or off an Exchange. Many of the more significant changes will have a direct effect on health insurance issuer revenue and federal funding levels.

Examples of changes that will affect issuer revenue are the modifications to the reinsurance and risk corridors programs that affect both 2015 and 2014 calendar year operations. These changes indicate that the agency is attempting to address the effects of the Administration’s “transitional policy,” which allows individuals to remain enrolled in plans that do not meet certain Affordable Care Act (ACA) requirements beyond 2014 (when they otherwise would be effective).