Consumers Union Recommendations: "Revise the regulation to cap the number of rating areas a state may propose as an alternative to (b)(3) at no more than fifteen rating areas.... Add a provision that triggers a special enrollment period 30 days in advance of a known triggering event. Extend the time frame for special enrollment to 60 days from the triggering event. When an insurer is responsible for the triggering event, require the insurer to provide 14 day advance notice to consumers before a special enrollment period commences.... [D]evelop strict standards to measure, evaluate, and penalize a health insurance issuer, employee, agent or other party acting on behalf of the issuer that is undertaking marketing practices that discourage enrollment of individuals with significant health needs in health insurance coverage."

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