Since the Affordable Care Act was signed into law on March 2010, the Obama administration has changed the law 43 times without Congressional approval. The Galen Institute has been keeping track of these administrative changes, which you can find here.

Apparently another illegal administrative action, which will cost the U.S. Treasury $3.5 billion, can be added to the list. Late last Friday, and conveniently before a long weekend, the Centers for Medicare and Medicaid Services announced in a guidance document it would have $7.7 billion in reinsurance payments to cover the losses Exchange plan insurers incurred in 2015.  But CMS is not entitled to $3.5 of the $7.7 billion it is giving away.