"The notice of benefit and payment parameters proposal is one of the longest regulatory issuances yet to emerge from the ACA implementation process -- 372 pages of preamble and regulatory text.... Viewed as a whole, the proposal illuminates more clearly than anything that has so far emerged from the implementation process what a monumental task Congress has set for the nation in trying to reshape a private, market-based, health insurance system to make it accessible to all but the poorest Americans, regardless of health status."