CMS is seeking emergency Office of Management and Budget (OMB) review of certain health insurance rate increase disclosure and review requirements necessary to implement its September 6, 2011 final rule on “unreasonable rate increases” under the ACA. As previously reported, the September rule extended rate increase disclosure and review requirements to health coverage sold through associations, even if the state does not include such coverage in its definitions of individual and small group market. Comments on the requirements will be accepted until October 21, 2011. In a related development, on October 7, 2011, HHS began posting information on insurance company justifications of rate increases of 10% or more.