Expert Perspectives

Sep 26, 2025 

Ruling in Challenge to Marketplace Rule: Initial Analysis and Implications for States 

On August 22, a federal District Court judge in Maryland stayed, on a nationwide basis, the implementation of several provisions in the Centers for Medicare & Medicaid Services  “Marketplace Integrity” final rule. Some of the stayed provisions are effective immediately, creating the need for immediate implementation decisions by states. This expert perspective describes the impacted provisions.

Sep 18, 2025 

Tracking State Preparation for the Rural Health Transformation Program

On July 4, 2025, President Trump signed budget reconciliation legislation (H.R.1) into law. It made sweeping changes to healthcare programs, cut Medicaid spending by $911 billion over 10 years, and will lead to significant coverage lossesTo address rural health concerns stemming from these cuts, H.R.1 includes $50 billion for a Rural Health Transformation Program (RHTP). This expert perspective highlights state action to create a transformation plan and prepare to apply for the RHTP, including issuing Requests for Information and other efforts to educate the public and gather stakeholder input.

Sep 5, 2025 

New Guidance Expands Pool of Individuals Eligible to Purchase Catastrophic Plans

On September 4, 2025, the U.S. Department of Health and Human Services (HHS) released guidance expanding eligibility for catastrophic health plans. HHS’ guidance significantly expands the universe of individuals eligible for these plans, with potential implications for consumers’ access to premium tax credits, states’ individual insurance markets, and premiums for both catastrophic and individual market plans.

Sep 5, 2025 

How H.R.1 Impacts Coverage for Non-Citizens

H.R.1, signed into law on July 4, makes dramatic changes to the Medicaid and Marketplace coverage landscape. These changes include provisions that scale back access to health coverage for many lawfully residing non-citizens, estimated to leave 1.3 million more immigrants uninsured. This expert perspective describes the provisions, which eliminate the availability of premium tax credits (PTCs) and federally-funded Medicaid and CHIP coverage for many non-citizens who have been eligible for these programs for years, and eliminate PTCs for the lowest income, lawfully present non-citizens who are subject to a waiting period before they qualify for Medicaid or CHIP.