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CMS Marketplace Integrity Proposed Rule Would Create Unnecessary Barriers to Accessing Comprehensive, Affordable Health Insurance
ACS CAN submitted comments opposing the proposed rule and outlined the far-reaching consequences it would have. According to CMS' own estimates, the rule would result in up to 2 million fewer individuals enrolling in coverage.
April 11, 2025
Washington, D.C. – Today, the American Cancer Society Cancer Action Network (ACS CAN) submitted comments in a letter to the Department of Health and Human Services (HHS) and Centers for Medicare and Medicaid Services (CMS) opposing the 2025 Marketplace Integrity Proposed Rule and outlining the consequences it would have on potentially millions of people who get their coverage through the Affordable Care Act (ACA) Marketplace, including cancer patients, survivors, and those at risk of developing the disease, if finalized as drafted.
If finalized, this proposed rule would make it harder for people to access affordable, comprehensive coverage by restricting and shortening open enrollment periods, requiring burdensome paperwork and fees, and creating other barriers that would put affordable health insurance out of reach for up to 2 million people. Many of these restrictions would lead to gaps in coverage and delays in care, including the requirement for pre-enrollment verification, which would involve extensive paperwork and time for processing before someone can enroll in coverage. This proposed rule would also rescind a Biden Administration rule aimed at removing barriers to care and ensuring more people can access affordable and comprehensive coverage by allowing DACA recipients to be eligible for ACA Marketplace tax credits or subsidies.
In the letter, Lisa Lacasse, president of ACS CAN, writes:
“Studies show that uninsured patients had substantially higher risks of presenting with late-stage cancers at diagnosis, especially for screen-detectable cancers and cancers with early signs and symptoms, for which access to care is critical for early diagnosis.
“By CMS’ own estimates between 750,000 to 2 million fewer individuals would enroll in qualified health plan (QHP) coverage in 2026 if this proposal was finalized. These estimates do not account for other recent agency actions such as the significant cuts to navigator grant funding and the reduction of CMS personnel which are likely to result in decreased enrollment. Nor do CMS estimates account for the potential expiration of the enhanced Affordable Care Act (ACA) tax credits which have contributed to the record-breaking enrollment in Marketplace plans since they were enacted by Congress in 2021. ACS CAN is concerned that these cumulative policies will result in fewer individuals having access to affordable, comprehensive coverage.”
As of early 2025, more than 24 million people across the country bought comprehensive health insurance coverage through the ACA Marketplace. This record-high enrollment was made possible in part by well-funded Navigator programs that help individuals enroll in coverage, as well as the enhanced premium tax credits (EPTCs) that have made coverage affordable for millions more Marketplace enrollees. Now that the administration has cut Navigator funding by 90% and the EPTCs are about to expire this year if Congress does not act, this proposed rule is even more dangerous.
Read the full letter outlining ACS CAN’s comments on the proposed rule HERE.
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