A recent federal court ruling blocked stricter ACA Marketplace eligibility and enrollment standards. For employers with employees on Exchange coverage, this means the current rules stay in place for now.
Background
On June 25, 2025, the U.S. Department of Health and Human Services (HHS) issued a final rule to tighten ACA Marketplace eligibility and enrollment rules, set to take effect August 25, 2025. Three cities, a physician coalition, and a small-business group sued, claiming the rule violated the Administrative Procedures Act and restricted access to affordable coverage. On August 22, 2025, a federal court in Maryland put key parts of the rule on hold while the case proceeds, using its authority under the APA to set aside agency rules more broadly than typical case-by-case injunctions.
Court Ruling
On June 12, 2026, the court ruled that HHS exceeded its authority and struck down key parts of the final rule, including new $5 premiums for fully subsidized re-enrollees, collection of past-due premiums before new coverage, tighter APTC eligibility, expanded special enrollment verifications, a shorter open enrollment window, and stricter income verification.
The court did uphold changes to the premium adjustment methodology used to set many ACA limits, including maximum annual out-of-pocket costs. Download the bulletin for more details.
