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 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 14, 2026
[HCA, THC, DVA, PRVA, ENSG, PNTG]: Mapping Provider 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 hospitals, dialysis centers, value-based care (VBC) providers, skilled nursing facilities (SNFs), post-acute care…
August 3, 2026
[HCA, THC, CYH, ARDT, UHS, Muni-backed] FY27 Inpatient Hospital Better Than Proposed but Medicare Payment Growth Slows
The FY27 Medicare inpatient hospital (IPPS) final rule was modestly more favorable than the proposal for acute care hospitals [HCA, THC, CYH, ARDT, UHS, MPT, muni-backed systems], increasing CMS’s projected aggregate payment increase by $1B….
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…
July 2, 2026
Hospital/ASCs: Proposed 340B Rate Cut, Imaging Site Neutral and Outpatient Surgeries Inure Benefit to For-Profits While Hit to Nonprofits/Govt Hospitals
For-profit hospitals [THC, HCA, CYH, ARDT, UHS] received some expected positive news – though the magnitude surprised us – in the CMS’s proposed CY27 hospital outpatient prospective payment system (OPPS) rule. Ambulatory surgery centers (ASCs)…
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 10, 2026
Hospitals, ASCs, Imaging Centers: Medicare Risk in Summer OPPS Proposal? [THC, HCA, CYH, ARDT, UHS, SGRY, UNH, RDNT]
While Medicaid and ACA enrollment concerns have dominated the policy overhang for hospitals this year, Medicare-related risks could move higher on investors’ radar with the release of CY27 hospital outpatient prospective payment system (OPPS) proposed…
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…
May 21, 2026
CMS Proposal Pushes DPP Restrictions but Near-Term Impacts on Hospitals, Nursing Homes Still Limited Due to Grandfathering
CMS’s long-awaited proposed rule implementing the One Big Beautiful Bill’s (OBBB) restrictions on state directed payment programs (DPPs) pushes the envelope a bit further than the statute itself, particularly for hospitals [HCA, THC, CYH, UHS,…