Compliance News Week Ending March 21, 2025

In this Article

Proposed Rule - 2025 Marketplace Integrity and Affordability

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule that if finalized may impact individual health coverage available through public Marketplaces beginning in 2026.

Among other things, the rule proposes:

shortening the open enrollment window to November 1 through December 15;

increasing eligibility verification and reconciliation requirements for premium tax credits;

and adjusting the methodology used to set premiums.

It is estimated that some of the changes may result in lower overall premiums. For applicable large employers who offer an individual coverage Health Reimbursement Arrangement (HRA) plan (e.g., ICHRA), a reduced premium for the lowest cost silver plan could make it easier to make an affordable offer of coverage.

A fact sheet including a link to the proposed rule is on the CMS website.

^{While every effort has been taken in compiling this information to ensure that its contents are totally accurate, neither the publisher nor the author can accept liability for any inaccuracies or changed circumstances of any information herein or for the consequences of any reliance placed upon it. This publication is distributed on the understanding that the publisher is not engaged in rendering legal, accounting, or other professional advice or services. Readers should always seek professional advice before entering into any commitments.}