October 29, 2026
[CNC, MOH, HCA, THC, UHS] Medicaid Work Requirements: Court Ruling, State Flexibility Temper Disenrollment Fears
We view today’s federal court ruling broadening medical frailty exemptions from the Medicaid expansion work and community engagement requirements as incrementally favorable for Medicaid insurers [CNC, MOH, ELV] and acute care and behavioral hospitals [HCA,…
October 26, 2026
[OSCR, CNC, ELV, HCA, THC, DVA, FRE.DE] ACA Verification Proposal Tests, Rather Than Resets, Exchange Stabilization
We view CMS’s 2028 ACA pre-eligibility verification proposal, released late Friday, as an incremental risk to exchange insurers [OSCR, CNC, ELV] and hospitals and dialysis centers [HCA, THC, ADRT, DVA, FRE.DE], rather than a new…
October 8, 2026
[RDNT, LMRI, Radiology Partners] CMS’s OPPS Imaging Site-Neutral Proposal Likely to Stick, Freestanding Imaging Still Poised to Benefit
Despite lopsided stakeholder opposition, we continue to expect CMS to finalize largely as initially sought its CY27 proposal cutting Medicare reimbursement for 337 common non-contrast imaging procedures at grandfathered off-campus hospital outpatient departments (HOPDs) while…
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….