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 22, 2026
[OSCR, CNC, HCA, THC, DVA, FRE.DE]: ACA Anti-Fraud Actions are More Noise Than New – and Potentially Material
This afternoon’s White House announcement of additional Obamacare anti-fraud actions does not change the direction of the ACA reset underway over the past year, nor our expectations for 2027 and 2028. While the actions appear…
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 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…