Exchanges - Final Rule Largely Finalized as Proposed, Payment Integrity Remains a Key Area of Focus

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Exchanges - Final Rule Largely Finalized as Proposed, Payment Integrity Remains a Key Area of Focus

Equity Research

Flash Comment — May 18, 2026

Managed Care

Exchanges - Final Rule Largely Finalized as

Proposed, Payment Integrity Remains a Key

Area of Focus

Our Call Stephen Baxter, CFA

On Friday (5/15) CMS released the final 2027 exchange rule. Payment integrity continues Equity Analyst | Wells Fargo Securities, LLC

Stephen.Baxter@wellsfargo.com | 212-214-8041

to be a key focus area in this market and the majority of the changes made in the

Mitchell Ostrovskyproposed remained intact in final rule.

Associate Equity Analyst | Wells Fargo Securities, LLC

Mitchell.Ostrovsky@wellsfargo.com | 212-214-7243

Initial Thoughts Thomas Muller

CMS Final Exchange Rule. On 5/15, CMS released the final Notice of Benefit and Thomas.Muller@wellsfargo.com | 332-214-6218

Payment Parameters for 2027, covering the exchange market. Final rule was largely James Lemmis

consistent with the proposed rule with focus areas on enhancing payment integrity, Associate Equity Analyst | Wells Fargo Securities, LLC

broker oversight, plan design and issuer flexibility. The final rule did not move forward with James.Lemmis@wellsfargo.com | 212-214-5336

any changes to alternative minimum MLRs despite being contemplated in the proposed

rule.

Key Provisions Unchanged. CMS kept key program integrity initiatives unchanged from

the purposed rule. CMS finalized pre-enrollment SEP verification requirement for FFE

states, which requires states to conduct verification for at least 75% of new SEP enrollees.

CMS also finalized the removal of the 150% FPL SEP beyond 2026, a move to 1 year

Failure to File and Reconcile beginning in 2028 for SBE and 2027 for FFE, and the re-