Last week, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule for 2018. According to the press release, the proposed rule includes “reforms that are critical to stabilizing the individual and small group health insurance markets to help protect patients.”

However, many of the policy changes in the proposed rule would harm consumers. For example, a recent analysis from the non-partisan Center on Budget and Policy Priorities explains that the proposed rule would reduce the advanced premium tax credits that help make plans purchased through the Marketplace more affordable for moderate-income individuals in families.

According to the analysis, the proposed rule would result in lower tax credits because it lowers the actuarial value standards for “silver” level plans. This means that premiums and the percentage of costs covered by the insurer would decrease, but deductibles and copayments for consumers would increase. Under the Affordable Care Act, tax credits for consumers purchasing coverage through the Marketplace are calculated based on the second lowest cost silver plan. By allowing for lower value silver plans, the new rule would force consumers to pay more out of pocket to maintain their current level of coverage.

Furthermore, the CMS proposed rule also includes provisions to require consumers to provide supporting documentation for special enrollment periods before they can enroll in coverage. The proposed rule would also permit insurance companies to collect any missed premium payments before allowing consumers to re-enroll. Both of these changes could lead to gaps in coverage for consumers or deter enrollment.

Finally, the proposed rule would reduce the open enrollment period for individual and small group health insurance plans from 13 weeks to 6 weeks, which would give consumer significantly less time shop around for and enroll in the best plan for them.