CMS Premium Rebate Guidance – Implications for States and Other Stakeholders

The COVID-19 pandemic has led to a substantial reduction in commercial health insurance claims. With issuers holding extra cash and enrollees and employers facing financial hardship, some issuers have responded with premium holidays or discounts.

This commentary summarizes recent guidance from the Centers for Medicare & Medicaid Services on permitting health insurance issuers to provide certain premium rebates for 2020 and the conditions rebates must meet.

The commentary also explains how the guidance affects key stakeholders and notes questions that remain unanswered.