Consulting Actuary Greg Fann’s actuarial report on the implications of reducing ACA risk adjustment transfer payments in the Alabama individual marketplace appear in regulatory comments submitted by Blue Cross and Blue Shield of Alabama (BCBSAL) on the Proposed 2023 Notice of Benefit and Payment Parameters. ACA rules allows states to reduce risk adjustment transfer payments up to 50%; Alabama has been the only state to implement this mechanism, and the proposed rule would eliminate future opportunities for other states. BCBSAL concurs with the proposed rule and supports the repeal of this opportunity for other states, and respectfully opposes the proposed rule’s grandfathered exception for Alabama. While Mr. Fann’s report is specific to the Alabama individual market, BCBSAL also opposes the reduction of this option in the small group market. Read the regulatory comments here: