The Centers for Medicare & Medicaid Services (CMS) issued the 2025 Marketplace Integrity and Affordability Proposed Rule on March 10, 2025. The proposed rule outlined several provisions with the goal to address waste, fraud, and abuse centered around enrollments considered to be improper, and asserts that current eligibility and enrollment rules have led to adverse selection. The proposed rule directly mentions that several policies would decrease enrollment and thus reduce federal costs.
After a bipartisan, unanimous vote in the PA General Assembly in 2019, Pennie, Pennsylvania’s Health Insurance Exchange, was created. Pennie’s comments to the proposed rule focused on all the ways provisions as well as highlighted three major points: Pennie’s enrollment trends were expected, Pennie’s system already deters unauthorized enrollment by brokers, and that Pennsylvania’s insurance market is stable and robust. Specific proposed provisions of additional concern are limiting open enrollment to 45 days, requiring a $5 premium payment for those current enrollees who are reenrolled in a plan with a $0 net premium, and amending the premium adjustment percentage methodology and de minimis range for plans subject to actuarial value requirements. These particular proposals would significantly raise the costs to purchase and use coverage. Pennie’s current open enrollment period is from Nov. 1 to Jan. 15. For the 2025 Open Enrollment Period, 496,661 Pennsylvanians enrolled in coverage with roughly 36,000 new enrollments between Dec.16 and Jan. 15 of the total new enrollments. View the 2025 Marketplace Integrity and Affordability Proposed Rule (CMS-9884-P) in its entirety.