Agencies Issue 2027 Notice of Benefit and Payment Parameters Final Rule

On June 5, 2026, we published an Alert regarding the U.S. Department of Health and Human Services (HHS), through the Centers for Medicare & Medicaid Services (CMS), issuing the final 2027 Notice of Benefit and Payment Parameters (NBPP) —the annual rule that updates policies for federal and state Health Insurance Marketplaces. On July 16, 2026, the U.S. District Court for the District of Maryland issued a nationwide preliminary injunction temporarily staying eight provisions of the rule pending further litigation. The stay preserves existing Marketplace rules for now and prevents CMS from implementing certain changes. Accordingly, we have updated our Alert to include information regarding the court decision. Although the NBPP does not have any direct impact on employer-sponsored group health plans, employers should monitor any changes to the Marketplaces, as shifts in the individual market can affect their employer-sponsored coverage.