Georgetown's Professor Katie Keith Unpacks HHS's Recent Proposed Affordable Care Act Rule

Over the past 12 years the Affordable Care Act (ACA) has reduced the total number of uninsured Americans and low-income individuals more specifically by over 50% and by over 66% for young adults. In 2025 the ACA insured a record breaking 45 million Americans: 24 million through the federal and state exchanges; and, 21 million via the ACA’s expansion of the Medicaid program. Having been under nearly continual attack by Republicans, the proposed 2027 ACA rule, announced February 9th (with comments due March 13), was highly anticipated. Within a week after it was announced, Professor Keith and her colleague Matthew Fielder authored three lengthy essays unpacking numerous proposed rule provisions. Top of line the authors noted the proposed, if finalized, will decrease marketplace enrollment by 2 million in 2027 (marketplace enrollment is already down this year by one million due to the Congress’s refusal or failure to extend COVID-era enhanced premium tax credits) and will increase ACA-related reporting & record keeping by approximately $1.34 billion every year.

The first of three Health Affairs’ Forefront essays by Katie Keith and Matthew Fielder is at: https://www.healthaffairs.org/content/forefront/hhs-proposes-sweeping-changes-2027-marketplace-plans-part-1

The second is at: https://www.healthaffairs.org/content/forefront/hhs-proposes-sweeping-changes-2027-marketplace-plans-part-2

The third is at: https://www.healthaffairs.org/content/forefront/hhs-proposes-sweeping-changes-2027-marketplace-plans-part-3

The proposed rule is at: https://www.govinfo.gov/content/pkg/FR-2026-02-11/pdf/2026-02769.pdf

CMS’ related press release is at: https://www.cms.gov/newsroom/fact-sheets/hhs-notice-benefit-payment-parameters-2027-proposed-rule

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