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)…
July 2, 2026
Home Health: Medicare Proposal Seeks Modest 3% PDGM Recoupment Cut but Ups Spending by 2.4% and Rates Even More
Home health (HH) agencies [PNTG, BTSG, AVAH, UNH, ADUS, Elara] received a favorable surprise in CMS’s proposed CY27 Medicare HH reimbursement rule, released Wednesday. The regulation includes: A temporary 3% recoupment adjustment, matching the final…
June 30, 2026
Quarterly Policy Catalysts 3Q26: Health Insurers & Providers
We present our quarterly outlook on the key catalysts for health insurers and providers. Entering 3Q, the negative policy bias that dominated 1H26 has eased as payers appear to have priced plans appropriately and medical…
June 25, 2026
[CVS, Walgreens, Muni Hospitals]: Cassidy 340B Draft Capping Contract Pharmacies and Overseeing 340B Face Long Odds; Other Regulatory Actions Likely in Motion
Senate HELP Chairman Bill Cassidy’s (R-LA) recently introduced 340B Drug Pricing Integrity and Affordability for Patients Act raises threats to 340B contract pharmacies (both brick-and-mortar and mail-order) [CVS and private Walgreens, and to a much…
June 25, 2026
[DVA, FRE.DE, Innovative Renal] Medicare Proposal: Large Dialysis Chains Do Relatively Better but Phosphate Binder Policy Falls Short
CMS’s CY27 proposed Medicare end-stage renal disease (ESRD) payment rule is likely to leave dialysis providers [DVA, FRE.DE, private Innovative Renal] somewhat disappointed. The agency declined to extend the transitional drug add-on payment adjustment (TDAPA)…
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 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…
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…