How the Final 2027 NBPP Reshapes the ACA Individual Market: Business Models Emerging From Non-Network QHPs, Decade-Long Catastrophic Plans, Direct Enrollment Distribution, and the EHB Defrayal Shift

CMS dropped the final 2027 Payment Notice in May. Most coverage called it routine deregulation. It is not. Three foundational ACA assumptions just got repealed inside 1,121 pages. Thread on what actually matters.

1/ Non-network QHP certification is finalized, effective PY 2028. QHPs no longer have to maintain contracted provider networks. Publish a benef…