Multistate letter challenges proposed federal rollback that could strip health insurance from millions, shorten enrollment, and raise costs for states and residents.
NEW JERSEY - New Jersey Attorney General Matthew J. Platkin, alongside the attorneys general of California and Massachusetts, has co-led a coalition of 24 jurisdictions in opposing proposed federal rule changes that would significantly restrict access to health insurance under the Affordable Care Act (ACA). The multistate letter, submitted to the U.S. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS), argues the changes are legally flawed and would result in widespread harm to residents and state health systems.
“Taking health insurance away from people is not only cruel, it’s also bad policy. If we want to lower health care costs, we need more people to have coverage—not less,” said New Jersey Health Commissioner Kaitlan Baston, MD, MSc, DFASAM. “Everyone gets sick. But without insurance, people don’t get routine preventive care, and they wait to seek treatment until they’re much sicker. That makes their treatment more expensive—and when people can’t afford the hospital bill, we all end up paying for it.”
The proposal in question—introduced by HHS and CMS—seeks to implement multiple regulatory revisions to the ACA framework. If enacted, the rule could cause between 750,000 and 2 million Americans to lose their health insurance coverage by 2026, according to estimates cited in the states' letter. This potential coverage loss would increase the number of uninsured individuals and raise uncompensated care costs, driving up premiums and straining state-funded health programs.
One of the most impactful changes would require all state-based ACA exchanges to shorten their open enrollment periods. In New Jersey, this would reduce the enrollment window by approximately six weeks, forcing it to end on December 15—down from the January 31 deadline used in recent years. The shortened timeline could lead to reduced enrollment, undermining recent progress made through Get Covered New Jersey, which reported a nearly 30% increase in sign-ups during the 2024–2025 enrollment period.
“New Jersey established GetCoveredNJ with the promise of providing residents with improved access to quality, affordable health coverage. Over the last five years we delivered on that promise, implementing numerous consumer focused policies leading to record enrollment each year. Now, due to the proposed federal rule, the flexibilities that allowed New Jersey to tailor GetCoveredNJ to best serve our residents is at risk,” said Justin Zimmerman, Commissioner, New Jersey Department of Banking and Insurance, which operates Get Covered New Jersey, and which submitted its own comment letter on the rule. “This proposal would severely impact our ability to maintain the current access to quality, affordable health coverage for over a half a million residents and derail the tremendous progress we have made in connecting New Jerseyans with the health coverage and care they deserve.”
The proposed rule would also permit insurers to deny coverage to applicants with a history of even a single missed premium payment—without requiring any notice to the affected individuals. States argue this measure is unjustified and would likely catch consumers off guard, potentially denying them necessary health coverage without due process.
Another provision would eliminate the special enrollment period (SEP) currently available to low-income individuals with household incomes at or below 150% of the federal poverty level. Additionally, the rule introduces new administrative hurdles for residents seeking coverage during life changes such as childbirth, marriage, or job loss—circumstances typically protected under existing ACA enrollment standards.
The proposed changes also seek to revoke ACA exchange eligibility for Deferred Action for Childhood Arrivals (DACA) recipients, reversing a 2024 rule that had expanded access to these individuals. If implemented, the rollback would bar DACA recipients—commonly referred to as Dreamers—from purchasing affordable health insurance through federal or state exchanges.
“The Trump Administration, in one of its first proposed regulations, is trying to make it harder to access health insurance for New Jerseyans and across the country,” said Attorney General Platkin. “That decision harms vulnerable populations and those who count on the Affordable Care Act, and it hurts everyone else too—because it drives up costs for all the States and our residents. I am proud to lead the fight against this idea, and I will continue to fight against any unlawful changes that deprive New Jerseyans of access to quality, affordable health care.”
In the comment letter, the coalition argues that the proposed rules are “arbitrary and capricious,” and therefore unlawful under the Administrative Procedure Act. The states emphasize that the changes would disrupt healthcare access, reduce enrollment, and increase costs for both consumers and state governments.
In addition to New Jersey, California, and Massachusetts, the letter was signed by attorneys general from Arizona, Colorado, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Maryland, Maine, Michigan, Minnesota, New Mexico, New York, Oregon, Rhode Island, Vermont, Washington, and Wisconsin.
The coalition urges the federal agencies to withdraw the proposed rule and maintain current ACA protections to ensure continued access to affordable, comprehensive health coverage.