On August 22, 2025, the U.S. District Court for the District of Maryland delayed key parts of a final rule that would have imposed stricter enrollment and eligibility standards for the Affordable Care Act’s (ACA) Marketplaces. Many provisions, originally set to take effect on August 25, 2025, are now postponed.
Background
On June 25, 2025, the U.S. Department of Health and Human Services issued a final rule to strengthen Marketplace enrollment integrity, aiming to curb fraud. Several cities and nonprofits sued, claiming the rule violates the Administrative Procedures Act (APA) and makes accessing affordable coverage more difficult.
The U.S. Supreme Court generally limits federal courts to granting relief only to lawsuit plaintiffs, unless a plaintiff requests a judge to set aside an agency rule under the APA, which can provide broader relief.
Court Injunction
The U.S. District Court for the District of Maryland has paused several key parts of the final rule on Exchange eligibility and enrollment while litigation is ongoing. These include:
- Enrollees in fully subsidized coverage who don’t update their eligibility on time must pay a $5 monthly premium until their information is confirmed;
- Insurers can require payment of overdue premiums before starting new coverage, as allowed by state law;
- Individuals who do not file and reconcile their federal tax return may lose eligibility for the advance premium tax credit;
- Special enrollment periods now require pre-enrollment eligibility checks;
- If reported income differs from trusted sources, additional verification is required; and
- If tax return data is missing, household income must be verified.
Other changes made by the final rule, including shortening the Exchange’s open enrollment period effective for 2027, remain in effect. Download the bulletin for more details.