September 26, 2025
Medicare Advantage RADV Audits in Legal Limbo, But Don’t Discount Its Resurrection [HUM, UNH, CVS, CNC, ELV, ALHC]
Medicare Advantage (MA) insurers [HUM, UNH, CVS, CNC, ELV, ALHC] received some positive legal news that for now neutralizes the concern of widespread Medicare audits and potential concomitant recoupments. However, yesterday’s federal district court ruling…
September 25, 2025
Obamacare Fix: Still Optimistic, But Not Clean or Near Term [OSCR, CNC, HCA, THC, UHS, ACHC]
We continue to be optimistic and think the odds have risen above 50% that Congress later this year reaches a compromise to “fix” the expiring enhanced Obamacare subsidies, which would further remove some of the…
September 10, 2025
Status of Medicaid Work Requirements Among States [CNC, MOH, CYH, HCA, THC, UHS, ACHC, MMS]
Headline risk to Medicaid insurers [CNC, MOH], hospitals [CYH, HCA, THC], behavioral providers [UHS, ACHC], and Medicaid contractors [MMS] is likely to ramp up in the coming months as 15 states take affirmative steps toward…
September 9, 2025
[Hospitals, Nursing Homes, Medicaid Providers] CMS Guidance on SDPs Fleshing Out OBBB; Possible Negative Bias?
Late Tuesday, CMS released a letter to state Medicaid offices with its preliminary interpretations of the One Big Beautiful Bill (OBBB) Act’s provision placing total payment limits on hospitals, nursing homes, and certain practitioners at…
September 3, 2025
Nursing Homes & DOJ’s Shot Across the Bow [ENSG, PACS, WELL, OHI, SBRA, LTC]
Tuesday’s announcement by the DOJ to join a 2016 False Claims Act (FCA) whistleblower lawsuit against non-profit ProMedica Health System and its HCR ManorCare nursing homes may represent a new front in attacking long-term care…
August 25, 2025
Court’s Stay of CMS’s Obamacare Rule Provisions Is Clear Positive Sign But Uncertain Policy Outlook Still Suggests Messy Sign-Up [OSCR, CNC, HCA, THC, UHS, HQY]
A federal district court’s ruling Friday to stay part of CMS’s Obamacare program integrity regulation is a positive development for exchange insurers [OSCR, CNC, ELV, MOH], hospitals [HCA, THC, CYH, ARDT, MPW, municipal-backed facilities] and…
August 18, 2025
[CVS, CI, UNH, ELV]: CA’s PBM Reform Bill Appears Next Up in PBM Fight
With California’s legislature coming back Monday from its summer recess for its final few weeks of the regular session, pharmacy benefit manager (PBM) legislation is still on the docket and likely to invite headline risk…
August 13, 2025
[PNTG, EHAB, BTSG, ADUS, AMED, AVAH, UNH]: Where Might CMS Go with Home Health Rates?
With slightly more than two weeks left in CMS’s comment period for the CY26 Medicare reimbursement proposal rule for home health [PNTG, EHAB, BTSG, ADUS, AVAH, AMED, UNH], we continue to expect mitigation from CMS’s…
August 7, 2025
Health Insurer / Provider Legislative Agenda: Band-Aid Likely in September CR, More Substantial Package Potentially Later in the Year
With the August recess in full swing for the next few weeks, the various healthcare-related legislative items on Congress’s to-do list (see below) remains lengthy for the rest of the calendar year. We are still…
August 3, 2025
Hospices, IRFs, IPFs: Thoughts on Final FY26 Medicare Payment Rules
Medicare’s final FY26 payment regulations for hospices [CHE, AMED, ADUS, PNTG, BTSG, Gentiva, Compassus, Elara], inpatient rehab facilities (IRFs) [EHC, SEM], and inpatient psych facilities (IPFs) [UHS, ACHC] aligned with expectations for: 1) slightly higher aggregate spending…