SHVS Analyzes CMS, IRS Proposed Rules on ACA Verification Rules
In a resource analyzing two federal proposed rules, State Health and Value Strategies (SHVS) reports that the IRS released a proposed rule on October 15 and CMS released a proposed rule on October 27 to implement premium tax credit and eligibility verification changes required by the 2025 budget reconciliation law (H.R. 1). SHVS states the CMS rule would end automatic re-enrollment for subsidized Marketplace consumers, require manual re-enrollment each year, and deny subsidies while eligibility is being verified, creating months-long waits for some consumers. The analysis says these changes would impose substantial new administrative burdens on State-Based Marketplaces, which would need to rebuild eligibility and enrollment systems, and notes the new requirements have an August 1, 2027 go-live date that SHVS says the rule is unlikely to be finalized in time to meet. SHVS also notes mitigation provisions, including an extended verification period, pended enrollment, and retroactive financial assistance, but says these may be complex or unworkable.