I'm not convinced that insurance fraud will actually be a big problem. Just do a random spot-check of all the policyholders that the insurance company is claim

I'm not convinced that insurance fraud will actually be a big problem. Just do a random spot-check of all the policyholders that the insurance company is claiming a subsidy for. If the amount claimed is more than x% over the amount calculated by the government, then the insurance company gets cut off. Right now, by forcing people to buy on-exchange to get the subsidy, we're essentially doing the spot-check interactively. This is putting tremendous load on the healthcare.gov back-end. There's no reason this couldn't have been done as a batch process instead.