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Federal Court Halts New ACA Enrollment Restrictions

A recent federal court decision has temporarily halted the implementation of several new restrictions on Affordable Care Act (ACA) Marketplace enrollment and eligibility. These new standards, finalized by the U.S. Department of Health and Human Services (HHS) in June 2025 and slated to take effect in August 2025, aimed to combat fraud within the Exchange system. However, a lawsuit filed by various groups and cities alleged the rule was improperly issued and created barriers to affordable healthcare. Consequently, on August 22, 2025, the U.S. District Court for the District of Maryland paused key provisions of the rule, including requirements for overdue premium payments, income verification processes, and eligibility for advance premium tax credits, while the litigation proceeds. This pause means that many of the stricter enrollment criteria will not be enforced as initially planned, though some other changes from the final rule, such as a shorter open enrollment period for 2027, remain in effect.

 

ACA Subsidies: Timeline of Changes and Impact

The Deep Dive with Fred and Lupe.
The Deep Dive with Fred and Lupe discuss the history of the ACA Subsidies.

Hear about the recent and upcoming changes to the Affordable Care Act (ACA) Marketplace enrollment, eligibility, and subsidies. One document details a federal court’s decision on August 22, 2025, to pause several new, stricter enrollment and eligibility standards issued by the U.S. Department of Health and Human Services (HHS) that were set to take effect shortly thereafter, following a lawsuit alleging improper issuance. The other source provides a timeline of subsidy changes, outlining how the original ACA rules were enhanced by the American Rescue Plan Act (ARPA) and the Inflation Reduction Act through 2025, but are scheduled to revert to the less generous original ACA structure in 2026 under the “One Big Beautiful Bill” (OBBB) law. This reversion, coupled with tighter verification, full tax credit recapture, and narrowed eligibility for some groups, is projected to result in higher costs for many enrollees and an increase in the uninsured population.