November 23, 2025
ASC Wins in Final CMS Rate Rule, Slight Hospital Wins but Lingering Concerns
Ambulatory surgery centers (ASCs) [SGRY, AmSurg, THC, HCA, UNH] secured some policy wins in the final CY26 Medicare outpatient prospective payment system (OPPS) rule, consistent with the July proposal (notably a broadened covered procedure list,…
November 17, 2025
CMS Provider Tax Guidance: More Details, But Not Necessarily Stricter or More Aggressive Interpretation [ARDT, CYH, HCA, THC, UHS, CNC, MOH, ELV]
CMS’s preliminary guidance to states on its interpretation of the One Big Beautiful Bill’s (OBBB) Medicaid provider tax provisions does not appear to tighten the screws on states, and thereby threaten hospitals [ARDT, CYH, HCA,…
October 21, 2025
Rural Health Transformation Program (RHTP): Seems Less About Hospitals and More About Systemic Change [CYH, ARDT, THC, municipal facilities, OMDA, TDOC, RDNT]
As the November 5 deadline approaches for state submissions to the highly anticipated $50 billion Rural Health Transformation Program (RHTP), uncertainty remains about whether – or even how – these funds will reach hospitals [CYH,…
September 9, 2025
[Hospitals, Nursing Homes, Medicaid Providers] CMS Guidance on SDPs Fleshing Out OBBB; Possible Negative Bias?
Late Tuesday, CMS released a letter to state Medicaid offices with its preliminary interpretations of the One Big Beautiful Bill (OBBB) Act’s provision placing total payment limits on hospitals, nursing homes, and certain practitioners at…
August 1, 2025
Hospitals, LTCHs, SNFs: Thoughts on Medicare’s Final FY26 Inpatient Rate Rules
Medicare’s final FY26 payment regulations for inpatient hospitals [HCA, THC, CYH, ARDT, UHS, MPW, municipal bond-backed facilities], long-term care hospitals (LTCHs) [SEM, Kindred], and skilled nursing facilities (SNFs) [ENSG, PACS, Providence] with implications for their post-acute…
July 22, 2025
Obamacare Enhanced Subsidy Debate – Where We Stand [OSCR, CNC, ELV, THC, CYH, UHS]
While exchange insurers (OSCR, CNC, ELV) and hospitals (THC, CYH, ARDT, UHS, HCA) try to figure out their Obamacare businesses for next year with the various regulatory and reconciliation-related changes leading to anticipated enrollment declines…
July 16, 2025
Medicare CY26 OPPS Proposal: Hospital Outpatient Departments a Loser While ASCs a Winner
Hospitals [CYH, ARDT, UHS, THC, HCA] were on the losing end of the stick under CMS’s proposed CY26 Medicare reimbursement rule for hospital outpatient departments (HOPDs) and ambulatory surgery centers (ASCs) for a variety of…
July 9, 2025
Reconciliation: Final Healthcare Provisions; Clarifying Tweaks to DPP Language and Overlooked Parts of Work Requirements
While we still agree with consensus about the negative bias towards hospitals and Medicaid insurers from the One Big Beautiful Bill Act (OBBA) signed into law last Friday, we note a few tweaks in the…
June 22, 2025
Obamacare: Program Integrity Rule Meets Overall Expectations, Though Relative Slight Improvement; Risk Remains
Amidst the behind-the-scenes Senate debate of its draft reconciliation bill, CMS made good on its threat to jettison improper and fraudulent Obamacare enrollment, impacting ACA insurers [OSCR, CNC, ELV, MOH] and hospitals / behavioral facilities…
June 17, 2025
Healthcare: Thoughts on the Senate Finance Draft’s Healthcare Provisions
The Senate Finance Committee’s (SFC) draft healthcare and tax portion of the reconciliation bill makes some changes, relative to the House-passed measure, but is overall consistent with that version, with the implications being lower Medicaid…