CMS’ proposed 2027 Notice of Benefit and Payment Parameters (NBPP) points to a notable shift in how ACA Marketplaces may operate moving forward, with an emphasis on expanding lower-premium plan options and giving states more responsibility for oversight. The proposal would broaden access to catastrophic plans and allow for more flexible benefit design, which could lower monthly premiums but often comes with higher deductibles and cost-sharing, meaning consumers may face greater overall costs when they actually need care. At the same time, new eligibility and verification policies, including changes to advance premium tax credit (APTC) processes, could introduce enrollment disruptions and add administrative complexity for both consumers and Marketplaces. For states, the rule offers increased flexibility but also added operational responsibility without additional federal funding. Taken together, the proposal reflects a shift toward more state-driven and market-oriented approaches, while raising important questions about affordability, access, and the stability of coverage over time.