Thread by @charles_gaba

⚠️ Welp. Seema Verma had a choice: Properly review & respond to every #NBPP2022 comment...or do a sloppy rush job before 1/20/21. Guess which route she chose?
acasignups.net/21/01/14/seema…

Every year CMS proposes various tweaks/changes to how the ACA is actually implemented called the Notice of Benefit & Payment Parameters (NBPP). Some are minor. Some are major. Some are good, some neutral, some evil.

2022's have a mix, but the evil ones are REALLY evil. 2/

The NBPP has to allow for a public comment period before it can be finalized. Usually this is 30 days. In this case, Verma tried to ram it through on short notice; only 26 days of public comment, which of course included Christmas eve/day. 3/

Here's my explainer from last month, when I put out a call for people to submit public comment. I focused on what I think would be the most devastating changes: 4/
acasignups.net/20/12/31/updat…

Here's the nutshell version. #3 would starve HC.gov of much-needed revenue for operations, outreach, marketing etc. #5 is the least-harmful of them. It's the other three which would risk gutting the ACA. 5/

Verma "solved" the problem of rushing by...splitting the NBPP rule in half: She approved the first four today (along w/a couple others not listed above), while reserving the wonkier stuff for "a future final rule" which I presume she'll never get around to before 1/20. 6/

As @bjdickmayhew noted, even splitting the "review" in half likely still didn't allow them enough time to do this half properly, given that they likely only had perhaps 4 working days to do so.

There are several ways to reverse/cancel these rules before they're implemented... 7/

...but each will still take time, resources, etc. when there's 1,000 other dumpster fires for the incoming Biden Administration & Dem-controlled Congress to put out at the same time.

So...add this one to the pile: /END
acasignups.net/21/01/14/seema…