Insights: Policy

Medicare FFS Reimbursement (Home Health)

CMS has issued the CY26 Home Health Agency (HHA) Final Rule. Under the rule, CMS will decrease payments by -1.3% (-$220m) for CY26 relative to CY25. Comprising that net update is a 2.4% market basket update, a -0.1% outlier payment decrease, a -0.9% prospective behavioral adjustment due to the continued implementation of the Patient-driven...

Medicare Advantage (CY27 Rulemaking Part I)

CMS has issued the “Part I” Proposed Rule governing Medicare Advantage (MA) plans for contract year (CY) 2027, which includes policy and technical changes to the program. The “Part II” proposed rule, which focuses on reimbursement levels, will likely be released in sometime between now and February 2026.

President Trump has continued to signal shifting positions on the soon-to-expire ACA enhanced subsidies (eAPTCs). Earlier last week, the White House backed away from releasing its plan for addressing this issue (which, reportedly, would have included a temporary and nearly as-is extension of the subsidies and a framework for a more fulsome...

Deposit Insurance

The 11/18 House Financial Services Committee (HFSC) hearing on the FDIC deposit insurance limit made clearer what up to that point key House Republicans had been generally signaling - that they have significant reservations about increasing the limit. Chair Hill (R-AK) expressed concern about “potential unintended consequences,” while other...

Bank Capital/Liquidity

Bank regulators last week issued their final eSLR rule, which is largely consistent with what they proposed earlier this year, reflecting a reduction in the ratio but not a full exemption for Treasuries. Industry trade associations (e.g., BPI, FSF, SIFMA) praised the final rule and noted it would allow for more intermediation in the Treasury...

Medicare Outpatient/ASC Reimbursement

CMS has issued the CY26 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) final rule. Under the rule, CMS will increase OPPS and ASC payments by an aggregate 2.6% for CY26 relative to CY25 ($8b and $450m increases, respectively). That rate update is comprised of 3.3% market basket update reduced by a proposed...