October 9, 2026
[HUM, CLOV, ALHC, UNH, CVS, ELV, CNC]: MA Star Ratings Raises Stake for Litigation Anew and Policy Debate
While last night’s widely telegraphed Star Ratings delivered clear winners [HUM, CLOV, Devoted Health (pvt)] and losers [ALHC] (and a mixed bag for UNH, CVS, ELV, CNC, and MOH), potentially underappreciated methodological choices by CMS…
October 6, 2026
[HUM, ALHC, UNH, CVS, ELV, CNC, CLOV] Appeals Court Seems Skeptical of CMS But RADV Overhang Not Going Away Completely
Following yesterday’s oral appellate arguments over HUM’s challenge to Medicare Advantage (MA) risk adjustment-related audit rules, we believe a majority of the three-judge panel is likely to side with the company and the lower court…
September 30, 2026
[Municipal Hospitals, HCA, THC, OPCH, CVS, MRK, PFE]: 340B Drug Reimbursement Expectations in the Final Medicare OPPS Rule
With CMS likely to release its final CY27 Medicare Hospital Outpatient Prospective Payment System (OPPS) rule in early November, we continue to expect a substantial cut to Medicare payment for 340B-acquired drugs administered in participating…
September 8, 2026
[CNC, OSCR, UNH, HUM, CVS, ELV, MOH, CI, HQY]: Mapping Payer Policy Risk / Upside by Congressional Control in November Elections
With the November elections less than two months away, we assess how different congressional outcomes could reshape the healthcare legislative agenda for health insurers, pharmacy benefit managers (PBMs), 340B contract pharmacies, and health savings account…
August 21, 2026
[HUM, ALHC, UNH, CVS, AGL, ASTH]: MA Tech Changes Rule Expectations: Stars Likely in Focus, Major Risk Adjustment Change Seem Less So
The pending Contract Year (CY) 2028 Technical and Policy Changes proposal for the Medicare Advantage (MA) insurers [HUM, ALHC, UNH, CVS, ELV, CNC, CLOV, MOH] and MA-exposed providers [AGL, ASTH] could be relatively more consequential…
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…
June 25, 2026
[CVS, Walgreens, Muni Hospitals]: Cassidy 340B Draft Capping Contract Pharmacies and Overseeing 340B Face Long Odds; Other Regulatory Actions Likely in Motion
Senate HELP Chairman Bill Cassidy’s (R-LA) recently introduced 340B Drug Pricing Integrity and Affordability for Patients Act raises threats to 340B contract pharmacies (both brick-and-mortar and mail-order) [CVS and private Walgreens, and to a much…
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 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 12, 2026
UNH’s Flat-Fee PBM Model Seems in Response to Rivals and Regulators [UNH, CI, CVS]
UNH’s new Optum Rx model, which shifts PBM and group purchasing organization compensation in its commercial business toward transparent flat fees, appears designed to modestly outpace similar transparency initiatives from CI and CVS while aligning…