Challenge to Market Integrity Final Rule Wreaks Havoc on Preparations for Open Enrollment

Groom Law Group

The Centers for Medicare & Medicaid Services Market Integrity and Affordability Final Rule was published on June 25, 2025. In response, three cities, a coalition of doctors, and an interest group representing small business owners brought a lawsuit challenging certain provisions of the Final Rule alleging they will shoulder increased costs or see their members lose health insurance coverage if the changes are implemented. On August 22, 2025, the District Court in Maryland partially granted and partially denied the plaintiffs’ motion for a stay, pending a final ruling on the merits of the case.  CMS filed an appeal and requested a stay of the stay of the changes to the de minimis ranges for actuarial value calculations. In this webinar on Wednesday, October 1, 2025 from 2:00 – 3:00 p.m. ET, we will cover:

• A brief overview of the Market Integrity Final Rule provisions, including overlap with the One Big Beautiful Bill, with an emphasis on the challenged provisions;
• The litigation challenging the Final Rule; and
• CMS and states’ response to the litigation.

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