On Thursday, October 12th, President Trump issued an executive order, entitled “Promoting Healthcare Choice and Competition Across the United States” (the “Executive Order”). The Executive Order directs the Departments of Treasury, Labor (“DOL”) and Health and Human Services (“HHS”) (collectively, the “Departments”) to consider issuing sweeping new healthcare rules and regulations in the wake of Congress’ inability to pass legislation to reform the Affordable Care Act (“ACA”).

The issuance of the Executive Order was followed late in the evening by press reports, which have since been substantiated by the Administration, that funding for ACA cost-sharing reduction (“CSR”) payments will cease. The stopping of CSR payments is expected to result in a spate of litigation by carriers, states, and other stakeholders that seek to keep CSR payments in place.

This alert addresses both of these important developments.


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April 20, 2023

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