Federal Policy
Maryland Court Enjoins Eight Provisions of CMS 2027 Marketplace Payment Rule
A federal district court in Maryland issued a preliminary injunction on July 16, 2026, blocking eight provisions of CMS's 2027 notice of benefit and payment parameters final rule. The enjoined provisions include expanded out-of-pocket maximums for bronze and catastrophic plans, broader catastrophic plan eligibility, relaxed network adequacy standards, and a new pathway for non-network plans to qualify as marketplace coverage. The court found plaintiffs likely to succeed on Administrative Procedure Act claims and that irreparable harm would occur without relief. The injunction took effect July 20, 2026, while the remainder of the rule proceeded as scheduled.
Why it mattersMedicaid MCOs in states with marketplace partnerships or serving dual-eligible populations must monitor whether enjoined network adequacy relaxations affect benchmark plan standards or coordination of benefits requirements.