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 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 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,…
March 30, 2026
Hospitals, Insurer, Home Care, HSAs, PBMs: What Is a Realistic Federal Healthcare Savings Target in Reconciliation?
As the prospects have risen for another budget reconciliation bill, so has the risk for another legislative round of healthcare spending cuts, pressuring insurers, hospitals and home care and hospice agencies as a partial pay-fors…
March 10, 2026
Medicaid Expansion Levels – Thoughts on Potential 2027 Enrollment Declines [MOH, CNC, ELV]
With Medicaid insurers [MOH, CNC, ELV] projecting more muted Medicaid enrollment changes for 2026 compared with the sizable attrition during the post-pandemic Medicaid unwinding – and little guidance on what comes next – investors are…
January 26, 2026
Medicare Advantage: CMS’s Negative Surprise of Flat Rates and Risk Adjustment Changes – What Now?
CMS’s negative surprise to Medicare Advantage (MA) insurers [HUM, UNH, ALHC, CVS, ELV, CNC] – which is also likely to spill over into weakness among insurers less or not exposed to this market [MOH, OSCR,…