The Washington Report
July 2, 2025
Note to Subscribers
While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.
Health
CMS Releases Final Regulations on ACA; Marketplace Integrity and Affordability
On June 20, 2025, the Department of Health and Human Services’ (HHS) Centers for Medicare & Medicaid Services (CMS) released final regulations setting standards for the health insurance Exchanges, as part of Affordable Care Act (ACA) coverage. The final regulations revise standards relating to the denial of coverage for failure to pay past-due premium; excludes Deferred Action for Childhood Arrivals recipients from the definition of “lawfully present;” establishes the evidentiary standard HHS uses to assess an agent's, broker's, or web-broker's potential noncompliance; revises the Exchange automatic reenrollment hierarchy; revises standards related to the annual open enrollment period and special enrollment periods; revises standards relating to failure to file and reconcile, income eligibility verifications for premium tax credits and cost-sharing reductions, annual eligibility redeterminations, de minimis thresholds for the actuarial value for plans subject to essential health benefits (EHB) requirements, and income-based cost-sharing reduction plan variations. The final regulations also revise the premium adjustment percentage methodology and prohibit issuers of coverage subject to EHB requirements from providing coverage for specified sex-trait modification procedures as an EHB. The final regulations are effective August 25, 2025.
The news release is available here.
A Fact Sheet is available here.
The final regulations are available here.
Aon Publications
SCOTUS Upholds State Ban on Transgender Treatments for Minors
In a 6–3 decision, the U.S. Supreme Court (SCOTUS) upheld Tennessee’s ban on certain transgender treatments for minors, finding that the law did not discriminate on the basis of sex.
The Aon bulletin is available here.