August 13, 2026
OSCR, CNC, ELV: Which Known Obamacare Policy Headwinds Remain After 2026?
Through 2028, Obamacare enrollment faces two statutory headwinds after the large, still unfolding 2026 reset: The 2027 narrowing of ACA subsidy eligibility for certain non-citizens. The 2028 installation of pre-enrollment subsidy eligibility verification. For exchange…
July 29, 2026
[CNC, CVS, UNH, HUM] CMS Raises Stakes for Standalone PDPs for CY27 Part D
Tuesday’s CMS release detailing the financial components of its CY27 standalone Medicare Part D program and its decision to sunset the related two-year Part D Premium Stabilization Demo suggest additional uncertainty for standalone Part D…
July 22, 2026
[CNC, MOH, HCA, THC, UHS]: Medicaid Work Requirement Litigation Thoughts
We think the July 28 federal court hearing on the 25 states and the District of Columbia’s request to preliminarily enjoin CMS’s interim final rule (IFR) for Medicaid community engagement (CE) requirements for the Medicaid…
June 18, 2026
[HUM, UNH, CVS, ELV, CNC, ALHC, MOH, CLOV, CI]: CMS Recalculates 2026 Star Ratings in Light of CLOV Ruling, But Financial and Legal Questions Remain
CMS informed Medicare Advantage (MA) insurers [HUM, UNH, CVS, ELV, CNC, ALHC, MOH, CLOV] that it is voluntarily recalculating their CY26 Star Ratings, which determine CY27 Quality Bonus Payments (QBP). Under the agency’s approach, released…
June 15, 2026
[OSCR, CNC, ELV, HCA, THC, CYH, UHS]: ACA Court Win Offers Limited Relief as Obamacare Enrollment Headwinds Remain
Last week’s ACA-related court ruling permanently, which enjoined key portions of the CY25 Obamacare regulation, may initially reassure insurers [OSCR, CNC, ELV] and hospitals [HCA, THC, CYH, UHS, ARDT] about certain enrollment-related program integrity headwinds….
June 2, 2026
[CNC, MOH, ELV, HCA, THC, CYH] Medicaid Work Requirements: Deferment to States with Tighter Oversight in 2028; CMS Projects 15% Enrollment Decline
CMS’s long-awaited interim final rule implementing the One Big Beautiful Bill’s (OBBB) Medicaid Community Engagement (CE) requirements largely aligns with our expectations that CMS would defer to states on program design and implementation, which we…
June 1, 2026
CLOV Star Ratings Legal Win Creates System Uncertainty but Potentially Strengthens HUM Appeal
Last week’s federal court ruling in favor Clover Health (CLOV) against CMS injects fresh uncertainty into the Medicare Advantage (MA) Star Ratings and quality bonus payment framework [UNH, HUM, ELV, CVS, ALHC, CNC, MOH]. While…
May 7, 2026
Medicare Advantage: Policy Risk Panoply
With 1Q26 earnings now largely complete for the major Medicare Advantage (MA) insurers [UNH, HUM, ALHC, CVS, ELV, CNC, MOH], near-term MA policy risks remain less acute, though far from extinguished. Congressional cuts remain unlikely…
May 1, 2026
Medicaid Work Requirements: Despite Certain Restrictive Actions, Overall State Flexibility Likely Limits Risk [CNC, MOH, HCA, THC, UHS]
A wave of state actions (AR, IA, ID, IN, MO, MT, NC, NE, NH) on Medicaid community engagement requirements (aka work requirements), spanning both accelerated implementation like today’s launch in NE and in some cases,…
April 21, 2026
Being Coy on BALANCE – How Could CMS and Insurers Get to Yes [UNH, ELV, HUM, CVS, CNC, CI, MOH]
UnitedHealth’s (UNH) comments on its earnings call this morning, responding to a question about potential participation in CMS’s BALANCE obesity drug model, suggest that further design changes will be required for it – and likely…