The report: www.medpac.gov/wp-content/u...

This is because the value of supplemental benefits (the difference between an enhanced plan's cost sharing and what standard cost sharing would have been) now count towards the "true out of pocket cost"

Presumably another reason why bids came in so high.

I usually feel safe assuming a lawsuit! (But I don’t know…an insurer or PLF type group finds a test case).

Do you have a guess for whether this is likely to survive a legal challenge, independent of what the next admin does? (Assuming someone sues).