July 9, 2025
The Centers for Medicare & Medicaid Services (CMS) finalized the 2025 Marketplace Integrity and Affordability rule, which includes a number of policies intended to address improper enrollments in Marketplace coverage and reduce improper federal spending on advanced premium tax credits (APTCs).
Provisions in the rule were finalized largely as proposed with some exceptions. Effective dates vary but the earliest are for the 2026 plan year; sunset dates vary by provision. Notably, CMS chose not to extend certain provisions to State-Based Exchanges (SBEs). Many of the finalized provisions are temporary measures to immediately tamp down on improper enrollments and the flow of federal funds.
Given the impending expiration of the enhanced APTCs (absent an extension by Congress), CMS believes it would be reasonable to accept some risk of future improper enrollments after these policies sunset, in favor of limiting overall disruptions as the market adjusts and sheds holdover improper enrollments. Congress also may make some of these temporary measures permanent in the upcoming reconciliation bill.
CMS estimates that between 725,000 and 1.8M people could lose coverage as a result of the rule, down slightly from the proposed rule estimate of 750,000 to 2 million.
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