Proposed ACA Rule Could Lower Costs and Strengthen Enrollment Integrity
For: Policy Analysts, Insurance Plans, Health Policy Experts, Health Brokerages, and Agents.
The Trump administration’s proposed changes to the Affordable Care Act (ACA) aim to combat enrollment fraud, reduce federal costs, and stabilize insurance markets. While states like New York are pushing back, the data suggests these reforms may be both necessary and beneficial.
What Is the New ACA Rule Proposal?
- Shorten the open enrollment period to end on December 15
- Require IRS-verified income to receive subsidies
- Restore pre-enrollment documentation for special enrollment periods (SEPs)
- Enforce payment of past-due premiums before issuing new coverage
- Eliminate continuous monthly SEP for low-income applicants
- Introduce a $5/month premium confirmation for zero-premium auto-renewals
Why the Trump Administration Supports These ACA Changes
- Over 6 million cases of income verification mismatch in 2022
- Estimated $20 billion in improper subsidy payments
- Widespread fraudulent enrollments without consumer consent
The proposal aims to curb these abuses while improving public confidence and long-term affordability of ACA subsidies.
How the ACA Rule Changes Could Lower Costs and Improve Integrity
The upcoming Affordable Care Act (ACA) rule changes are designed to strengthen the individual insurance marketplace by tightening verification, limiting misuse of special enrollments, and ensuring subsidies go only to those who qualify. These changes are expected to yield wide-reaching improvements in both cost efficiency and program integrity.
1. Reduce Enrollment Fraud
The revised rules emphasize more rigorous documentation, especially for individuals enrolling during a Special Enrollment Period (SEP). Applicants must now provide evidence to validate qualifying life events and income claims, including verification through IRS tax filings.
Previously, limited documentation requirements created opportunities for ineligible individuals to receive subsidies or enroll based on exaggerated or false claims (such as a non-existent job loss or divorce). By enforcing stricter standards, the government ensures that financial assistance is distributed fairly and only to those who meet eligibility criteria.
This approach helps preserve the credibility of the ACA program and protects limited public resources from misuse.
2. Lower Premiums and Stabilize Risk Pools
Adverse selection has been a persistent issue in ACA markets. It occurs when people delay enrolling until they need medical care, resulting in a risk pool skewed toward higher-cost individuals. This drives up premiums and destabilizes the market.
With better enforcement of SEP rules and limited enrollment opportunities, the new regulations aim to reduce opportunistic enrollment. This encourages people to maintain continuous coverage rather than joining only when necessary.
By creating a more balanced mix of healthy and sick individuals, insurers face less financial uncertainty, leading to more stable premiums and lower rate increases for all enrollees.
3. Increase Insurer Confidence
Health insurers have long cited unpredictability and late premium payments as key reasons for withdrawing from ACA exchanges. The rule changes include shortened grace periods for delinquent payments and stricter enforcement of enrollment timelines.
These measures reduce the number of enrollees who receive care but fail to pay premiums or who sign up briefly and then cancel. This gives insurers better visibility into enrollment patterns and risk exposure.
The increased predictability and reduced administrative burden help insurers remain in the marketplace and may encourage others to return or expand their coverage areas. As a result, consumers could benefit from more plan choices and greater competition.
4. Save Taxpayer Dollars
One of the most compelling arguments for the ACA rule changes is the potential for significant federal savings. Improper subsidy payments due to fraud or insufficient income verification have cost billions. By tightening eligibility controls and reducing unnecessary claims, the government can avoid these expenses.
Estimates suggest that the cumulative savings could range from $11 to $14 billion by 2027. These savings stem from:
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Fewer erroneous subsidy payments
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Lower premiums and reduced subsidy amounts
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Improved coordination with IRS data to avoid overpayments
This reduces the fiscal burden on taxpayers and strengthens the long-term sustainability of the ACA program.
Why New York Opposes the Changes—and Why It Might Be Wrong
- The changes are redundant due to existing safeguards
- Premiums may rise 4.5%
- Up to 6,000 enrollees could lose coverage
However, national trends suggest:
- Even “secure” exchanges are vulnerable to fraud
- Removing fraudulent or improper enrollees can improve risk pools
- New York’s robust Medicaid/Essential Plan programs offset enrollment losses
- One-time IT upgrade costs are offset by federal subsidy savings
Impact on Insurers, Taxpayers, and ACA Marketplace Stability
The ACA rule changes represent more than administrative reform — they’re a deliberate strategy to increase the efficiency, integrity, and financial health of the Affordable Care Act system. By reinforcing eligibility verification, streamlining enrollments, and promoting responsible participation, these changes positively impact three major stakeholder groups: insurers, taxpayers, and beneficiaries.
Insurers: A More Predictable and Sustainable Environment
For insurers participating in the ACA marketplace, predictability and risk management are crucial. Over the years, issues such as high turnover (churn), inconsistent payments, and late enrollments have created a volatile operating environment. The upcoming rule changes aim to reverse that trend.
Stronger Payment Compliance
Tighter rules around grace periods and enforcement of premium payment deadlines reduce the number of consumers who receive coverage and file claims without paying their premiums in full. This strengthens insurer cash flow and limits financial losses from non-compliant enrollees.
Fewer Unpaid Claims and Less Market Churn
When enrollees sign up during Special Enrollment Periods but drop coverage after using services — a behavior sometimes referred to as “churn and burn” — it results in a flood of unpaid claims and administrative burden. The new verification and compliance mechanisms limit these behaviors, stabilizing enrollment throughout the year and allowing insurers to better manage costs.
More Accurate Premium Pricing
With better data on who is enrolling and when — and fewer unpredictable cost spikes from late enrollees — insurers can make more accurate actuarial projections. This leads to:
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More stable premiums year over year
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Fewer unexpected mid-year rate increases
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A healthier overall risk pool
Together, these effects restore confidence among insurers, encouraging more of them to stay in the exchange or re-enter markets they previously exited.
Taxpayers: Greater Efficiency and Accountability in Government Spending
Since premium tax credits are funded with federal dollars, protecting the integrity of subsidy distribution is essential for both fiscal responsibility and public trust. The ACA rule updates help safeguard taxpayer resources in meaningful ways.
Billions in Federal Savings
Estimates from CMS and the Treasury Department indicate that increased verification and fraud prevention measures could save the federal government $11–14 billion by 2027. These savings are driven by:
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Fewer improper subsidy payments
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Lower insurer losses (which indirectly impact premiums and subsidies)
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Improved plan pricing across the board
These financial gains mean that tax dollars go where they’re needed most — helping truly eligible individuals maintain coverage — rather than subsidizing those who game the system.
Improved Transparency and Accountability
By linking ACA subsidies to IRS-verified income and enforcing SEP documentation standards, the government builds greater transparency into the system. This reduces the likelihood of fraud, improves oversight, and makes it easier for watchdogs and the public to track how federal resources are used.
Over time, this can increase bipartisan support for the ACA, simply because it becomes a more trustworthy and fiscally sound program.
Beneficiaries: Greater Continuity, Stability, and Trust
For ACA enrollees — especially those in low-to-moderate income brackets — the rule changes help reinforce coverage reliability and fairness in access.
Better Coverage Continuity
By discouraging opportunistic enrollment and penalizing lapses in premium payments, the rules encourage beneficiaries to maintain ongoing coverage. This means:
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No gaps in care
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Better long-term health outcomes due to uninterrupted access to treatment and medication
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Reduced administrative disruption from frequent disenrollments and re-enrollments
Reduced Surprise Disenrollments
In past years, many individuals were unknowingly dropped from their plans due to missed payments or unverified SEP events. With clearer enrollment timelines, tighter enforcement, and up-front documentation, enrollees are more likely to stay covered without unexpected surprises.
More Trust in the ACA System
As beneficiaries experience more consistent coverage, transparent plan pricing, and a fairer system overall, their trust in the ACA grows. They can count on their insurance being there when they need it, and they understand what’s expected of them to maintain eligibility.
This is especially important in building long-term engagement among historically underserved or skeptical populations.
Conclusion: Are ACA Rule Changes a Path to Sustainability?
By creating a more controlled, transparent, and accountable environment, these ACA rule changes reduce volatility and uncertainty across the marketplace. That leads to:
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Lower premiums due to improved risk pooling
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More plan options as insurer confidence rises
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Increased enrollment among those who may have previously avoided the system due to confusion or lack of trust
Ultimately, these improvements aren’t just about cost control — they’re about creating a marketplace that works better for everyone: fairer for consumers, sustainable for insurers, and responsible for taxpayers.
Bottom Line: Program integrity isn’t bureaucratic red tape—it’s the foundation for a resilient, affordable ACA marketplace.