Essential Community Provider (ECP) Reviews
An Essential Community Provider (ECP) certification criteria refers to the requirements that QHPs include “within health insurance plan networks those ECPs, where available, that serve predominately low-income, medically- underserved individuals.” [23]
HHS is proposing to conduct Essential Community Provider (ECP) certification reviews in FFEs for states performing the plan management functions. ECP data has been submitted for review in the ECP/Network Adequacy (ECP/NA) template, which is submitted directly to HHS when the state is not performing plan management functions. However, if the state is performing the plan management functions, they are submitted to SERFF and system limitations have caused HHS to not be able to receive reliable data. HHS believes their recent system improvements will now allow them to conduct reviews beginning with plan year 2026.
Exchanges
Exchange User Fees
An exchange user fee is a percentage of premiums that are collected to fund exchange activities. Annually, HHS sets separate user fees for FFEs and SBE-FPs.
The FFE user fee was proposed to be 2.5% of total monthly premiums for benefit year 2026, and 2.0% for the SBE-FP.[24] However, this assumes that the enhance PTC subsidies will not be extended. If they are extended by the end of March, HHS expects to lower the proposal to between 1.8%-2.2% for the FFE user fee and between 1.4%-1.8% for SBE-FP due to the expectation of higher enrollment.
Assistance with Financial Assistance Programs
HHS noted their concern about the significant outstanding medical bills that are currently in collections. While Assisters and Navigators are available to help consumers make informed decisions about picking their health plan, HHS is soliciting comments about how Assisters and Navigators may be utilized to direct customers to financial assistance programs.[25] They specifically noted assister programs located within hospitals or as part of hospital systems.
[23] D. Part 156—Health Insurance Issuer Standards Under the Affordable Care Act, Including Standards Related to Exchanges – 8. Essential Community Provider Reviews for States Performing Plan Management (§156.235)
[24] D. Part 156—Health Insurance Issuer Standards Under the Affordable Care Act, Including Standards Related to Exchanges – 2. FFE and SBE–FP User Fee Rates for the 2026 Benefit Year (§156.50)
[25] C. Part 155—Exchange Establishment Standards and Other Related Standards – 1. Solicitation of Comments—Navigator, Non-Navigator Assistance Personnel, and Certified Application Counselor Program Standards (§§155.210, 155.215, and 155.225)