CHIRblog (Center on Health Insurance Reforms)

What’s Worse than a Ghost Network Plan? A No-Network Plan

The Trump administration’s 2027 Notice of Benefit & Payment Parameters (NBPP) would allow ACA Marketplace insurers to sell “non‑network” plans that set a fixed payment amount for services instead of contracting with providers. Under the proposal, patients would be responsible for any balance‑billing if a provider refuses the plan’s rate. The rule would contravene ACA mandates for a sufficient in‑network provider choice, essential‑community‑provider inclusion, and out‑of‑pocket caps. Critics warn the model could destabilize Marketplace pricing, risk‑adjustment mechanisms, and consumer protections.