November 19, 2025
Finance Committee Hearing: Still Think ACA Subsidy Deal is More Likely Even If Late [OSCR, CNC, CYH, UHS, DVA, FMS, HQY, WBS]
This morning’s Senate Finance Committee hearing on rising healthcare costs did little to break the stalemate on Obamacare, but no one expected a breakthrough today. The hearing primarily served as a venue for both sides…
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,…
October 6, 2025
Still Optimistic on Obamacare Subsidy Fix with Reforms, But Less So on Age Rating and Reinsurance [OSCR, CNC, ELV, CYH, THC, HCA, UHS, ACHC]
Nearly a week into the government shutdown, with the parties dug in, we continue to expect Congress to “fix” the enhanced Obamacare subsidy cliff, benefiting exchange insurers, hospitals, and behavioral health providers. The questions remain…
September 10, 2025
Status of Medicaid Work Requirements Among States [CNC, MOH, CYH, HCA, THC, UHS, ACHC, MMS]
Headline risk to Medicaid insurers [CNC, MOH], hospitals [CYH, HCA, THC], behavioral providers [UHS, ACHC], and Medicaid contractors [MMS] is likely to ramp up in the coming months as 15 states take affirmative steps toward…
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 7, 2025
Health Insurer / Provider Legislative Agenda: Band-Aid Likely in September CR, More Substantial Package Potentially Later in the Year
With the August recess in full swing for the next few weeks, the various healthcare-related legislative items on Congress’s to-do list (see below) remains lengthy for the rest of the calendar year. We are still…
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…