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,…
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 25, 2025
Obamacare Fix: Still Optimistic, But Not Clean or Near Term [OSCR, CNC, HCA, THC, UHS, ACHC]
We continue to be optimistic and think the odds have risen above 50% that Congress later this year reaches a compromise to “fix” the expiring enhanced Obamacare subsidies, which would further remove some of the…
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 25, 2025
Court’s Stay of CMS’s Obamacare Rule Provisions Is Clear Positive Sign But Uncertain Policy Outlook Still Suggests Messy Sign-Up [OSCR, CNC, HCA, THC, UHS, HQY]
A federal district court’s ruling Friday to stay part of CMS’s Obamacare program integrity regulation is a positive development for exchange insurers [OSCR, CNC, ELV, MOH], hospitals [HCA, THC, CYH, ARDT, MPW, municipal-backed facilities] and…
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…
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…