Insights: Clients

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.

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...

It’s been reported that the White House was yesterday planning to release a legislative proposal for addressing the ACA enhanced subsidies (eAPTCs) that expire at the end of this year. The proposal will apparently extend the subsidies for two years, but with modest revisions around eligibility (700% income threshold) and various waste/fraud/abuse...

Mergers & Acquisitions

Compass/Anywhere

The HSR-waiting period is set to expire on December 1. Our ongoing research continues to suggest a high probability of a second request and a potential basis for litigation, but we still expect the deal will be conditionally cleared. It is evident that the combined company will have a dominant share in certain large MSAs (e.g., San Francisco Bay...