Consumers Union comments to the Centers for Medicaid and Medicare Services (CMS) expressing concerns with its proposed rule intended to stabilize the insurance marketplace. We believe the NPRM will not achieve its stated purpose. In fact, we believe the rule will have the contrary effect. The cost reductions and regulatory simplifications set forth in this proposed rule accrue mainly to the benefit of issuers, while the bulk of the costs and impediments to access will be borne by consumers. The stated purpose acknowledges “some uncertainty ” regarding the net effect on enrollment, but all signs in fact point to reduced enrollment in the Exchanges due to additional hurdles for consumers, including both healthy ones and those who know they need care.