Pre-Enrollment Verification Regulation
CMS released a proposed regulation around pre-enrollment verification. Starting in 2028, consumers applying for advance premium tax credits (APTCs) or cost-sharing reductions (CSRs) through the ACA Marketplace would be required to verify key eligibility criteria such as income or citizenship, each year. If a Marketplace cannot verify the information, the consumer will be ineligible for APTCs or CSRs until it is verified. CMS estimates that these changes could reduce enrollment by 300,000, although it also projects that over 5 million people could have their coverage disrupted. Comments are due on November 27th.
Medicaid Directors Concerned About Work Requirements Implementation
State Medicaid directors, through the National Association of Medicaid Directors (NAMD), expressed concerns about the IT development needed to implement work requirements and other Medicaid eligibility changes because of H.R. 1. Fierce Health has a helpful summary of the NAMD discussion here.
Earnings Updates
Several insurance companies released information as part of their quarterly earnings announcements. Molina reported that it expects its 2026 medical-cost trend to range from 5.0% to 5.5%, while it anticipates state rate increases averaging about 4.5%. For 2027, Molina expects rate increases of approximately 6%. Meanwhile, Centene announced that recent Medicaid rate increases, including off-cycle and retroactive adjustments, have helped offset elevated costs associated with behavioral health, home health, and high-cost medications.
STAR Ratings Litigation
CVS has sued CMS over its 2027 Star Ratings, joining Alignment Healthcare, Centene, Healthfirst, and SCAN Health Plan in challenging aspects of the 2027 ratings methodology. CVS estimates that its current ratings could reduce 2028 Medicare Advantage revenue by more than $2 billion.
340B Litigation
The Missouri Attorney General issued a cease-and-desist letter to Eli Lilly over its policy requiring 340B hospitals to submit claims-level data before receiving statutory drug discounts. Several Massachusetts hospitals have also sued over the policy in federal court.
