May 28, 2026
Surprise Billing: Pro-Providers, But Legal Questions Remain [NUTX, TeamHealth, Radiology Partners]
This morning’s final rule revising operations of the No Surprises Act (NSA) federal independent dispute resolution (IDR) process does not seem to upset the balance that has favored certain out-of-network specialist physicians and hospitals [NUTX,…
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,…
May 18, 2026
Hospitals: Latest CMS Batch of Approved Hospital-Specific DPPs [HCA, CYH, THC]
Two long-anticipated hospital-specific Medicaid state directed payment programs (DPPs) in Florida and Indiana, benefitting HCA, CYH, and THC and other hospitals in those states, appear to have been approved by CMS in recent weeks, according…
May 13, 2026
Hospice / Home Health Moratorium Headwind & Advantages for Established Operators [CHE, PNTG, EHAB, BTSG]
CMS’s announcement of a six-month moratorium on new hospice and home health agency enrollment in Medicare is the latest escalation in the administration’s broader crackdown on alleged waste fraud, and abuse, reinforcing its ongoing targeting…
May 12, 2026
UNH’s Flat-Fee PBM Model Seems in Response to Rivals and Regulators [UNH, CI, CVS]
UNH’s new Optum Rx model, which shifts PBM and group purchasing organization compensation in its commercial business toward transparent flat fees, appears designed to modestly outpace similar transparency initiatives from CI and CVS while aligning…
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,…
April 27, 2026
Dialysis – CY27 Medicare Bundle: Phosphate Binders and Monthly Add-on Remain Swing Factors [DVA, FRE.DE, Innovative Renal]
With the CY27 Medicare end-stage renal disease (ESRD) payment proposal now under OMB review, uncertainty surrounding the extra payments for oral phosphate binders to dialysis centers [DVA, FRE.DE, private Innovative Renal] may emerge as an…
April 24, 2026
Hospice: Program Integrity Still Overhang, but Large Agencies Insulated; How SSVI May Be Tweaked [CHE, PNTG, BTSG, ADUS, AVAH]
CHE’s comments on its 1Q26 earnings call this morning regarding the government’s efforts to rein in Medicare waste, fraud and abuse in hospice reinforce our prior views that program integrity, instead of the sufficiency of…
April 21, 2026
Another State PBM Ban on Pharmacies Invites Headline Noise – and Ultimately Legal Challenges [CVS, CI, UNH]
While the passage of another ban on PBM ownership of pharmacies – this time in Tennessee – could reignite some headline risk for CVS, CI, and UNH, we think the actual risk of it going…