Current Federal Market Proposal Imposes New Necessities for States and Customers

By Sabrina Corlette and Jason Levitis*

On March 10, 2025, the Facilities for Medicare & Medicaid Providers launched a proposed regulation that makes a number of coverage and operational modifications to the Inexpensive Care Act (ACA) Marketplaces and insurance coverage guidelines. A central tenet of the proposed rule is that Biden-era insurance policies to enhance Market premium affordability and ease administrative hurdles to enrollment have contributed to widespread fraudulent or in any other case improper enrollments. CMS makes use of this argument to justify modifications that would cut back Market premium tax credit, improve paperwork necessities for candidates and enrollees, and roll again eligibility. The proposed rule doesn’t, nonetheless, acknowledge that improper enrollments are concentrated within the Federally Facilitated Market, although most State-Based mostly Marketplaces (SBMs) adopted, and in lots of circumstances expanded upon, the insurance policies in query. Additional, whereas CMS acknowledges that broker-driven fraud is a key reason for improper enrollment, the proposed rule doesn’t embrace provisions that may impose limits on brokers’ habits or exert authority over lead mills and different actors driving fraudulent enrollments.

Of their newest Professional Perspective for the State Well being & Worth Methods program, CHIR’s Sabrina Corlette and the City Institute’s Jason Levitis present an evaluation of what the proposed rule means for SBMs and state insurance coverage regulators. The total submit could be discovered right here.

*Jason Levitis is a Senior Fellow within the Well being Coverage Division on the City Institute.