Comment on Proposed Rule CMS-2025-0020-0011, CHLP (April 11, 2025)

CHLP submitted this public comment in opposition to CMS-2025-0020-0011 “Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability,” a proposed rule that would affect coverage offered through the Affordable Care Act.

CHLP's letter argues that the proposed rule would severely reduce health insurance coverage for millions of people, particularly affecting marginalized communities. It emphasized the harm this rule would cause to people living with HIV, those affected by racial and gender discrimination, and economically disenfranchised populations. Of particular concern are provisions targeting Deferred Action for Childhood Arrivals (DACA) recipients and transgender and gender non-conforming (TGNC) individuals by eliminating Marketplace coverage for DACA recipients and prohibiting coverage of gender affirming care, such as puberty blockers and hormone treatments, as an essential health benefit. CHLP characterizes these moves as unscientific, discriminatory, and contrary to long-standing medical standards, further marginalizing groups already facing significant healthcare access barriers.

The letter further criticizes the rule's broader implications, including increased costs, administrative burdens, and coverage limitations that would reduce access to preventative care and treatment—particularly for people living with or vulnerable to HIV. The proposed rule is part of a broader pattern of attacks on evidence-based healthcare and underserved populations. CHLP's letter warns that these changes would lead to worse public health outcomes, exacerbate health inequities, and contribute to the criminalization of health conditions and urges the rejection of the proposed rule and reaffirms the right of all people, especially those historically excluded from care, to access comprehensive, culturally competent health services.