Case Information
*1 Case 1:25-cv-02114-BAH Document 36 Filed 08/22/25 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND * CITY OF COLUMBUS ET AL.,
* Plaintiffs,
* v.
* Civil No. 25-2114-BAH ROBERT F. KENNEDY, JR. ET AL.,
* Defendants.
* * * * * * * * * * * * * *
ORDER
For the reasons stated in the accompanying memorandum opinion, it is, by the United States District Court for the District of Maryland, hereby ORDERED that:
1. Plaintiffs’ motion for a stay under 5 U.S.C. § 705 or, in the alternative, for a preliminary
injunction, ECF 11, construed as a motion for a stay under 5 U.S.C. § 705, is GRANTED in part and DENIED in part;
2. The effective dates of the following provisions of the final rule entitled “Patient
Protection and Affordable Care Act; Marketplace Integrity and Affordability,” 90 Fed. Reg. 27074, are STAYED pursuant to 5 U.S.C. § 705 pending a final ruling on the merits of this case:
a. The imposition of a $5 premium penalty on automatic re-enrollees, through the
addition of 45 C.F.R. § 155.335(a)(3) and (n) and revisions to 45 C.F.R. § 155.330(j);
b. The revocation of guaranteed insurance coverage for individuals with past-due
premiums, through revisions to 45 C.F.R. § 147.104(i); c. The failure to reconcile policy in 45 C.F.R. § 155.305(f)(4), including the final
rule’s amendments to that policy through the addition of 45 C.F.R. § 155.305(f)(4)(iii);
d. The imposition of eligibility verification for the special enrollment period,
through the revisions to 45 C.F.R. § 155.420(g); *2 Case 1:25-cv-02114-BAH Document 36 Filed 08/22/25 Page 2 of 2
e. The imposition of a requirement that Exchanges verify household income
inconsistencies when a tax filer’s attested projected annual household income differs from “trusted data sources,” through revisions to 45 C.F.R. § 155.320(c)(3)(iii);
f. The changes to the de minimis ranges for actuarial value calculations, through
revisions to 45 C.F.R. §§ 156.140(c), 156.200(b)(3), and 156.400. 3. The Court DECLINES to stay the effective dates of the following provisions:
a. The change to the measure for calculating the premium adjustment percentage
set forth in 90 Fed. Reg. 27,166 through 27,178; b. The elimination of the 60-day extension of time to resolve inconsistencies in
household income data, through the removal of 45 C.F.R. § 155.315(f)(7) and revisions to 45 C.F.R. § 155.320(c)(5).
SO ORDERED.
Dated: August 22, 2025 /s/ Brendan A. Hurson
United States District Judge 2
