"[The Inspector General's] report ... certainly does not establish the extent to which individuals who are not eligible for enrolling in a QHP or receiving [advance premium tax credit (APTC)] or [cost-sharing reduction payments (CSR)] are in fact being allowed to do so. And it does not prove that fraud is infecting the program.... CMS also reiterated ... its intention to begin collecting transparency information on qualified health plans ... CMS states in the notice that it intends to implement later ... [the] reporting requirements for health plans other than QHPs, and may delay reporting to state exchanges as well... it is unclear on what basis the agencies have authority to delay implementation and impose different requirements for non-QHP health plans."