On August 22, a federal District Court judge in Maryland stayed, on a nationwide basis, the implementation of several provisions in the Centers for Medicare & Medicaid Services (CMS) “Marketplace Integrity” final rule. The Court also found no statutory basis for CMS’ long-standing “failure to reconcile” rules in either their new or existing form and stayed those rules as well. Some of the stayed provisions were to take effect immediately, creating the need for immediate implementation decisions by states. This State Health and Value Strategies expert perspective explains the affected provisions, the court's rulings, and expected next steps in the litigation.