Chad Brooker advises clients on the short- and long-term impacts of healthcare reform on their business strategy and advocacy priorities.

He has special expertise in health insurance regulatory compliance and product innovation as well as in public and private health insurance marketplaces.

Prior to joining Avalere, Chad was regulatory counsel and manager of Policy and Strategy for Connecticut’s Health Insurance Exchange, Access Health CT. In this role, he provided counsel to senior leaders and insurance plan executives around strategic development and compliance, with respect to marketplace reforms, regulations, and healthcare related tax laws. Prior to that, as a health insurance specialist in the Exchange Policy Operations Group at the Centers for Consumer Information and Insurance Oversight, he wrote federal regulations on health insurance reform and Affordable Care Act (ACA) exchanges and advised exchanges and health plans on ACA and marketplace implementation, market standards, and QHP certification.

Chad has a JD with certifications in health law and business law from the University of Maryland School of Law and a BS in economics and mathematics and a BA in political science and policy studies from Syracuse University.

Authored Content

The Centers for Medicare & Medicaid Services (CMS) issued a new Interim Final Rule (IFR) that is intended to allow additional beneficiaries, especially those who are at high-risk, to receive home infusions amid COVID-19 transmission concerns. Specifically, the CMS clarified the definition of “homebound” under the Medicare Home Health Benefit and temporarily suspended enforcement of the National and Local Coverage Determinations (NCD and LCD) related to home infusion services. Uncertainties remain as to how these new flexibilities will be utilized, as well as how these flexibilities could impact treatment outcomes.

In the fourth episode of this series, Avalere experts discuss the impact of the COVID-19 pandemic on care delivery and the future of telehealth.

New flexibilities for telehealth services in fee-for-service (FFS) Medicare are designed to support ongoing COVID-19 response efforts.

On March 2, the Supreme Court (SCOTUS) announced that it will review an appeal of the 5th Circuit Court of Appeal’s decision in Texas v. Azar regarding the legality of the Affordable Care Act’s (ACA’s) individual mandate and other provisions.

The Center for Medicare & Medicaid Services (CMS) recently issued its proposed Notice of Benefit and Payment Parameters (NBPP) for the 2021 plan year. The proposed rule would significantly expand commercial payer flexibility to not count manufacturer copay support toward deductibles or out-of-pocket (OOP) maximums.

In the Notice of Benefit and Payment Parameters (NBPP) for the 2021 plan year, CMS questioned whether states were appropriately deciding if the state was required to defray the premium impacts of new benefit mandates added since 2011. CMS proposes requiring states to report on and justify defrayal decisions for all state benefit mandates.

With new cell and gene therapies poised to revolutionize treatment for a growing number of disease states, stakeholders are working to reimagine existing value and reimbursement models to meet the special challenges these breakthrough services present.

CMS is considering changes to its commercial market Risk Adjustment Data Validation (RADV) program to improve the accuracy of risk adjustment transfers and to increase stability and predictability for issuers. This follows issuer experiences with the 2017 RADV process in which some issuers saw substantial, unforeseen changes to their risk adjustment transfers. These RADV changes have the potential to impact issuer participation and premiums in future years depending on the direction (positive or negative) and magnitude of those transfers.

Final rule by the Treasury Department, Department of Labor, and the Department of Health and Human Services reverses previous Treasury Department guidance blocking tax-advantaged HRAs that were not integrated with a comprehensive employer-sponsored plan.

While the Department of Health & Human Services (HHS) did not intend for proposed changes to Anti-Kickback Statute (AKS) regulations to impact commercial market drug negotiations, some state laws may indirectly lead to commercial market implications.

The Centers for Medicare & Medicaid Services released the final Notice of Benefit and Payment Parameters (NBPP) for the 2020 plan year. This annual rule, released today, updates guidance and regulations related to exchanges as well as the broader individual, small group, and large group insurance markets.

New analysis from Avalere finds that exchange plan sign-ups could decline by 1.1 million, while premiums could increase by 6.3%, by 2025 should HHS finalize recently proposed changes to auto-reenrollment in the exchange and the calculation of tax credit subsidies.

The swift proposed implementation timeline will require stakeholders to evaluate quickly operational requirements, behavioral responses, cross-program implications, and impact on contractual arrangements.

The Centers for Medicare & Medicaid Services released the proposed Notice of Benefit and Payment Parameters (NBPP) for the 2020 plan year. The rule could limit exchange plan enrollees' access to certain brand name drugs and increase the out-of-pocket costs within plans.

Listen to Avalere experts discuss the implications for a recent decision ruling the Affordable Care Act is Unconstitutional.

A proposed rule released by the Treasury Department, Department of Labor, and Department of Health and Human Services would expand the allowed uses of employer-sponsored Health Reimbursement Arrangements (HRA). Comments on the rule can be submitted until December 28, 2018.

On September 22, California became the sixth state to limit or ban short-term limited-duration insurance (STLDI) plans.

Average premiums projected to grow 3.1% heading into next year.

On June 19, the Department of Labor (DOL) released its final rule on Association Health Plans (AHP).

2019 rate filings suggest increased competition and plan choice

New analysis from Avalere finds that the proposed rule on association health plans (AHPs) is projected to lead to 3.2M enrollees shifting out of the Affordable Care Act's (ACA) individual and small group markets into AHPs by 2022.

This past Friday, the Centers for Medicare & Medicaid Services released the proposed Notice of Benefit and Payment Parameters (NBPP) for the 2019 plan year.