Policies & Analysis

The City of Columbus, the Mayor and City Council of Baltimore, the City of Chicago, Doctors for America, and Main Street Alliance have challenged the new 2025 Marketplace Integrity and Affordability Rule promulgated by the Centers for Medicaid and Medicare Services (CMS) and implemented by the U.S. Department of Health and Human Services (HHS). Plaintiffs argue that this rule undermines the availability of insurance under the Affordable Care Act (ACA) and violates the Administrative Procedure Act. Plaintiffs seek temporary and permanent injunctions to vacate the 2025 Rule.

A group of 20 states, led by the state of California, have sued the Trump administration for sharing Medicaid patients' private information with the Department of Homeland Security (DHS). The Trump administration has altered Medicaid rules to allow patient information to be shared with immigration enforcement in order to prevent non-citizens from receiving Medicaid benefits. The plaintiffs argue that these changes violate the Medicare and Medicaid Act as well as the Social Security Act.

A coalition of twenty-one states have filed this lawsuit against the U.S. Department of Health and Human Services (HHS), and the U.S. Centers for Medicare & Medicaid Services (CMS). Plaintiffs challenge a June 2025 Final Rule promulgated by HHS, which they allege imposes multiple new barriers to enrollment under the Affordable Care Act (ACA). The Final Rule shortens open enrollment periods, increases verification requirements for special enrollment, imposes a $5 monthly charge on certain $0-premium enrollees, and excludes gender-affirming care from coverage defined as Essential Health Benefits. Plaintiffs contend that the rule violates the Administrative Procedure Act (APA) because it is arbitrary and capricious, inconsistent with the ACA, and was issued after only a 23-day comment period without adequate justification. Plaintiffs seek declaratory and injunctive relief, including vacatur of the Final Rule, to prevent its implementation.