Each year, CMS issues key documents that issuers rely on to develop plans and rates for the upcoming plan year. This week, CMS released three operational and technical guidance documents that include helpful information that issuers should rely on to help them successfully offer plans both on and off Exchange in plan year 2027. 

• Final 2027 Actuarial Value (AV) Calculator and User Guide: CMS requires use of an AV calculator by issuers of non-grandfathered health insurance plans offered in the individual and small group markets, both on and off the Exchanges, for the purposes of determining levels of coverage. Under the Affordable Care Act, AV must be calculated based on the provision of essential health benefits to a standard population. The statute groups health plans into four tiers: bronze, with an AV of 60 percent; silver, with an AV of 70 percent; gold, with an AV of 80 percent; and platinum, with an AV of 90 percent.
  • The 2027 version of the AV Calculator closely resembles the 2026 version. The main differences are updates to the trend factors, an update to the MOOP limit check, use of a blend of EDGE 2021-2023 claims data, and an update to the annualization factor.
  • The Final 2027 AV Calculator is available for download. Issuers should use the new 2027 AV Calculator and User Guide as they develop plans for the 2027 plan year.
• Final 2027 AV Calculator Methodology: Along with the 2027 AV calculator, CMS also released a methodology document which provides background information on the regulatory authority allowing HHS to make updates to the AV Calculator and a detailed description of the development of the standard population and the 2027 AV Calculator methodology.
• 2027 Draft Letter to Issuers in the Federally-facilitated Exchanges (FFEs): The 2027 Draft Letter provides updates on operational and technical guidance for the 2027 plan year for issuers seeking to offer qualified health plans, including stand-alone dental plans, in the FFEs or the Federally-facilitated Small Business Health Options Programs. It also describes how parts of the 2027 Draft Letter apply to issuers in State-based Exchanges on the Federal Platform. Issuers should refer to these updates to help them successfully participate in these Exchanges in 2027. Similar to previous years, the 2027 Draft Letter focuses on guidance that has been updated for the 2027 plan year, and refers issuers to the 2017 through 2026 version of the Letter in all instances where CMS guidance has not changed.
  • CMS welcomes comments on the proposed guidance included in the 2027 Draft Letter by sending comments to PMpolicy@cms.hhs.gov by March 23, 2026. CMS notes that comments would be most helpful if organized by the subsections of this 2027 Draft Letter. 

In addition to these key operational and technical guidance documents, CMS also recently published the HHS Notice of Benefit and Payment Parameters for 2027 Proposed Rule. The deadline to submit comments on the proposed rule is March 13, 2026. For more information on the policies in the proposed rule, check out Groom’s recent publication:

• CMS Issues 2027 HHS Notice of Benefit and Payment Parameters Proposed Rule | Groom Law Group