Insights^

Find our analysis on legislation, regulations, MedPAC meetings, and more. 

Highlights from December 2025 MedPAC Meeting

On December 4 and 5, 2025, the Medicare Payment Advisory Commission (MedPAC) met to discuss recommendations for the March 2026 Report to Congress. Many of the sessions during this two-day meeting focused on evaluating payment rates for physicians, inpatient services, outpatient services, home health services, and services provided in institutions such as skilled nursing facilities (SNFs). There was also discussion about the quality of care Medicare beneficiaries receive across different settings, including hospitals, outpatient settings, other facilities, and at home.

PHYSICIAN AND OTHER HEALTH PROFESSIONAL SERVICES RATES

MedPAC staff offered a comprehensive view of current spending and service use under the Medicare

Physician Fee Schedule (PFS), followed by a discussion of access-to-care and quality-of-care metrics. There was a change in the provider mix, with more advanced practice nurses (APRNs) and physician associates (PAs) providing care. MedPAC staff found that Medicare Economic Index (MEI) growth outpaced PFS updates, and suggested that increasing compensation rates is not necessary to maintain wide access to care. The Chair’s draft recommendation is for Congress to increase payment rates by 0.5% more than current law, resulting in a 1.25% increase for advanced alternative payment model (A-APM) clinicians and a 0.75% increase for other clinicians.

The Commissioners expressed widespread support for the Chair’s recommendation. One Commissioner was unsupportive, indicating that, due to inflation, the proposed increase in payment would result in a net decrease of 2.2%. A few other Commissioners acknowledged this point but felt that increasing the rate more would lead to ballooning costs. There was sentiment that the reimbursement policy needs an overhaul, as the current system is squeezing providers and not benefiting either providers or patients.

Some Commissioners suggested that staff begin taking a closer look at the effects of concierge care and at how to quantify its use. There was also strong support for crafting new survey questions to measure quality of care, as the Merit-based Incentive Payment System (MIPS) is flawed. One Commissioner also noted that comparison data between private insurance options and Medicare is helpful, but if the comparison group is worsening, that does not automatically mean Medicare access and quality are improving.

HOSPITAL INPATIENT AND OUTPATIENT SERVICE RATES

MedPAC staff found hospital supply and availability were relatively steady for fiscal year 2024 (FY24), with Medicare inpatient stays and outpatient services increasing in 2024. Hospital margins increased slightly but remained low. Relatively efficient hospitals’ margins also increased from -2% to -1% in 2024. MedPAC staff also said that the Medicare Safety-Net Index (MSNI) remained a better predictor of hospitals’ all-payer operating margins than other metrics. The Chair’s draft recommendation for 2027 payments is to update the 2026 Medicare base payment rates by the amount specified in current law, and to implement MSNI as described in the March 2023 report, adding $1 billion to the MSNI pool.

There was general support for the recommendations, with many Commissioners specifically mentioning strong support for the MSNI contribution. Two Commissioners expressed reservations about supporting the recommendation because they wanted separate Inpatient Prospective Payment System (IPPS) and Outpatient Prospective Payment System (OPPS) measures and recommendations.

The Commissioners were very interested in the efficient hospital model and in how it has been previously validated. There was also general interest in how the model is used; however, the Chair pushed for the committee to remain on the topic of recommendations and suggested revisiting the conversation at a later date. A few Commissioners asked how $1 billion was determined as the amount to contribute. The staff and the Chair clarified that it was about 0.5% of a rate increase and that additional information on the expected effects of the contribution would be provided.

POST ACUTE CARE: TRENDS AND KEY ISSUES

This presentation was suggested to evaluate, holistically, post-acute care facilities’ use and payment. The differences in eligibility requirements, benefits, and cost-sharing requirements make it difficult to conduct a one-to-one comparison of quality outcomes, but preliminary results indicate possible inefficient care. There are plans for future work to evaluate the new case-mix systems, monitor the TEAM alternative payment model, compare Medicare Advantage and fee-for-service (FFS) use of post-acute care, and examine Medicare Advantage’s impact on the financial performance of SNFs and inpatient rehabilitation facilities (IRFs).

The largest discussion thread was the desire for more data to support future recommendations. Measures such as patient experiences and outcomes, as well as how providers select facilities, were among the suggestions. There was discussion on the 3-midnight rule and the inclusion of observation status for post-acute care facilities. MedPAC previously recommended that observation be included, but there have been no further changes. Another large topic of commentary was understanding geographic locations of each type of post-acute care facility and how location may influence patient placement.

While the presentation stated that there are no guidelines for patient placement, one Commissioner responded that the rehabilitative specialties do have guidelines, along with their clinical judgement, for evaluating patients. This led to the suggestion that these guidelines be collected and examined to understand how they are used, and that the reports be reformatted as needed.

SKILLED NURSING FACILITIES RATES

The MedPAC presentation on SNFs suggested that SNF access has remained stable for Medicare beneficiaries, as the number of SNFs decreased while occupancy rates increased. Quality measures were also noted as being stable, but there are gaps in quality data since patient experience data is not uniformly collected. Margins for freestanding SNFs were high in 2024, averaging 24.4%. The Chair’s draft recommendation for 2027 rates is to reduce 2026 Medicare base payment rates for SNFs by 4%. The expected implications are a decrease in spending relative to the current law, but no adverse effect on access to care.

The design of nursing home star ratings was evaluated, and an alternative approach was proposed that would equally weight each domain. The idea is that it would increase the weight of the staffing rating. It was also suggested that the change in approach could provide a more complete picture of quality and compliance for SNFs.

There was broad support for the recommendation, with some saying that it is a conservative reduction in payment due to the high margins SNFs experience. There was commentary on ways to more accurately reflect SNF star ratings by changing domain weights, with some Commissioners suggesting a higher staffing weighting and others arguing that the other domains are equally necessary. It was also suggested that CMS overhaul the measures used to evaluate quality and compliance. More long-term thinking about paying for outcomes and care was raised as an avenue for the commission to explore.

HOME HEALTH CARE SERVICES RATES

MedPAC staff provided an overview of home health care services and spending, showing that access to care has remained adequate. They also highlighted that the overall use of home health services has declined by 1%, but Los Angeles, California, has seen rapid growth in the area. This has led to a usage rate of about twice the national average and has been accompanied by a rapid rise in costs. While some tools have been used to address program concerns, use remains high. Quality of care has also remained stable, and home health margins have remained high, averaging 21.2%. The Chair’s draft recommendation for 2027 is for Congress to reduce the 2026 Medicare base payment rate for home health services by 7%. The expected implications would be to decrease spending with no adverse effect on access to care.

A few Commissioners asked MedPAC staff whether what was being seen in California represented the start of a larger trend and requested a closer look at the differences in California’s usage rates. There was interest in whether the higher home health usage was offset by lower usage of other post-acute care settings, such as SNFs and IRFs. One Commissioner, who practices in Los Angeles County, offered some commentary he believed could explain the differences. In his opinion, low property tax rates encourage older populations to age in place and choose home health services over other types of care. Another possibility is the availability of remote home monitoring equipment, which makes it easier for patients and providers to feel comfortable with home health programs. The Commissioner encouraged MedPAC staff to examine discharge-to-home rates in Los Angeles County compared to the rest of the country to understand if the high usage of home health services results in lower emergency department readmission rates.

Other discussion topics revealed that Medicare FFS is the preferred payer for home health services, above both Medicare Advantage and private health insurance. A better understanding of the payer mix is a topic that multiple Commissioners expressed interest in revising. Other data points that future work could examine include utilization rates, especially comparisons between rural and urban communities, as well as utilization by living status.

Overall, there was broad support for the Chair’s draft recommendation. The only hesitation was why a 7% rate cut was chosen over similar rates, especially when compared with other draft recommendations. The Chair explained that the Commission is trying to preserve access and quality while signaling the feeling that rates need to be lowered. Some long-term planning to examine whether a single large rate cut or a series of smaller rate cuts over a longer period was preferred was suggested.

Week Ahead: Winter Chills and APTC Thrills

As a polar vortex threatens the Northeast and Midwest with cold temperatures, lawmakers looking to extend the expiring enhanced advance premium tax credits (APTCs) are feeling the heat. With only eight days left before Congress is set to leave for the holiday recess, advocates are hoping for a cooling of relations between party leadership to avoid a blue Christmas. So, let’s get into it. Welcome to the Week Ahead!

The Administration

It’s all about moving forward at the Department of Health and Human Services (HHS) these days.  HHS announced its major AI strategy, “OneHHS” where all divisions will work together on a Department-wide AI infrastructure to boost internal operations, research, and public health.  But that isn’t the only collab HHS is working on.

Turning heads, a new Center for Medicare and Medicaid Innovation model called ACCESS was announced, which will test expanded access to new technologies by offering outcome-based payment incentives to primary care clinicians.  Bolstering this model will be the Food and Drug Administration’s TEMPO pilot, which will evaluate a risk-based enforcement approach to new digital health devices.  Together, the two models will help the agencies understand the interaction between access, cost, and improved care.

Speaking of models, CMS teased a new Accountable Care Organization (ACO) model called LEAD to be released in December.  The 10-year model will use an updated financial benchmarking approach, risk arrangements, and wellness incentives.

But, wait, where is the administration on APTCs??  The future is now.

The Senate

The Senate is expected to consider legislation to extend the enhanced APTCs this week, fulfilling Senate Majority Leader John Thune’s promise to Democrats in exchange for their votes to reopen the government. Senate Democrats are planning on bringing forward a three-year clean extension of the subsidies – legislation that mirrors the bill House Democrats have been trying to get enough signatures for to force a House floor vote.

There has also been talk about Senate Republicans bringing a bill forward that would redirect enhanced APTC funding to health savings accounts (HSAs), but only for marketplace enrollees with bronze or catastrophic plans, since they are now eligible for HSAs under the One Big Beautiful Bill Act.   Then there is the latest float by Republican Senators Bernie Moreno (OH) and Susan Collins (ME) that  would eliminate zero-premium plans and cap income eligibility for APTCs.

However, Leader Thune has not yet announced plans to move forward on this bill. Based on our conversation, both bills would fail to reach the 60-vote threshold required to pass the Senate. And even if the Democratic bill passed the Senate, it would be DOA in the House.

It will also be important to watch what happens at the Senate Homeland Security and Governmental Affairs Investigations Subcommittee hearing entitled, “Defining Our Healthcare Problem and Principles We Should Follow to Solve It.” This hearing, scheduled for December 10, is likely to see some fireworks, as Sen. Ron Johnson (R-WI), an avid Affordable Care Act critic, chairs the subcommittee. We will also be watching for potential wild cards, such as Sen. Bernie Moreno (R-OH), who is working on a short-term enhanced APTC extension provided reforms are made, and Sen. Jon Fetterman (D-PA), who supports an enhanced APTC extension, but has shown a willingness to break with his party when it comes to strategy on how to get that done.

Meanwhile, Senators have made progress on another health care issue that has long garnered bipartisan support: pharmacy benefit manager (PBM) reform.  Senate Finance Committee Chair Mike Crapo (R-ID) and Ranking Member Ron Wyden (D-OR) introduced legislation to address concerns about certain PBM practices that have been criticized for driving up prescription drug costs and limiting transparency. Our conversations on the Hill support the idea that this bill, or similar PBM reform legislation, could pass along with larger legislation, such as legislation that will be needed to continue government funding beyond January 30, 2026.

Other Health Care Hearings

  • December 11: Senate HELP hearing on the Future of the U.S. Organ Procurement and Transplantation Network

The House

If you were to just listen to House Republican and Democratic leadership, you’d think negotiations over the extension of the enhanced APTCs were as frozen as a pond in winter. But beneath the surface, there are signs of a breakthrough. Most notably, a group of 35 bipartisan representatives, led by Reps. Jen Kiggans (R-VA) and Josh Gottheimer (D-NJ), introduced a health care framework outlining a two-year plan to extend the enhanced APTCs, phase them out for certain enrollees, and institute reforms to address fraud concerns. This framework also calls for PBM reforms and lists other health care policies as potential reforms to pursue, including boosting the Medicare Physician Fee Schedule and health care price transparency requirements.

But if negotiations are like a frozen pond, don’t expect to go swimming just yet. House Majority Leader Steve Scalise (R-LA) has said the Kiggans-Gottheimer framework is “not been a part of the package we’re discussing.” Additionally, both Speaker Mike Johnson (R-LA) and Leader Scalise have been hinting that their conference is close to unveiling its own health care reform legislation. This could be as soon as this week (if you ask Speaker Johnson), but certainly within the next few weeks, according to Leader Scalise.

There You Have It

Washington celebrated a couple of annual traditions with the lighting of the Capitol Christmas tree on December 2 and the lighting of the National Christmas tree on December 4. Are decorations up at your house? Let us know. Make it a great week!

Senate HELP Committee Hearing on Health Care Affordability

On December 3, 2025, the Senate HELP Committee held a hearing on health care affordability. The main topic of the day was what to do about the enhanced advance premium tax credits (APTCs), which expire at the end of the year. Democratic senators, and a few Republican senators, argued that the APTCs need to be extended. Most Republican senators countered that the enhanced APTC funding should be provided directly to patients through tax-free accounts. Senators from both parties also brought up other policy proposals to address health care costs. These included proposals to create a Medicare-for-all system, reform certain pharmacy benefit manager (PBM) practices, and strengthen price transparency requirements.

Opening Statements

Witness Testimony

  • Joel White, President, Council for Affordable Health Coverage – Testimony
  • Marcie Strouse, Owner and Partner, Capitol Benefits Group – Testimony
  • Claudia M. Fegan, MD, National Coordinator, Physicians for a National Health Program – Testimony

Member Discussion

Enhanced APTCs

All Democrats in attendance, as well as Sens. Susan Collins (R-ME), Lisa Murkowski (R-AK), and Jon Husted (R-OH), agreed that the enhanced APTCs should be extended for at least a year, with Democratic senators proposing an extension of up to 3 years. There were also differences of opinion on whether it would be a clean extension or involve unspecified reforms. Dr. Fegan agreed there should be an extension of the enhanced APTCs and stated multiple times that an increase in cost, even minimal, is associated with patients waiting longer to seek care, which in turn leads to more preventable deaths. Chairman Cassidy (R-LA) countered that the enhanced APTCs go directly to insurance companies and not individuals.

Chairman Cassidy and Sen. Roger Marshall (R-KS) were the strongest supporters of funding health savings accounts (HSAs). They argued that this solution directly addresses high deductible and out-of-pocket costs, which Mrs. Strouse supported. However, Sens. Patty Murray (D-WA) and Andy Kim (D-NJ) raised concerns that this solution would still require individuals to purchase insurance, which may be unaffordable for them. Mr. White’s counter was to allow premium costs to be paid with HSAs. Chairman Cassidy also rebutted arguments against directing enhanced APTC dollars to HSAs, noting that funded HSAs would accompany Bronze and Copper ACA plans, which have lower premiums and high deductibles that would be offset by the HSAs.

Other Proposals

Ranking Member Bernie Sanders (I-VT) was vocal about his support for a Medicare-for-all approach and the need to designate health care access as a human right. He argued that a Medicare-for-all proposal would reduce administrative costs, therefore saving money. He suggested the committee should hold a hearing with health officials from countries with universal health coverage and lower per-person costs.

Sen. Tim Kaine (D-VT) suggested that the committee consider previous efforts that had strong bipartisan support, such as PBM reform. Sen. Kaine argued that this could reduce consolidation for health care providers, which the panel was in favor of, though Mrs. Strouse did feel that it could not be a “one size fits all” approach to reform.

There was also a lot of discussion about increasing price transparency and allowing for price shopping. Sen. Husted indicated he would be introducing a bill in the coming days that would allow for greater competition through plan price transparency. Sen. Marshall highlighted S.2355, the Patients Deserve Price Tags Act, which would allow patients to know the cost of care before they receive it.

Sen. Josh Hawley (R-MO) suggested that health care spending, such as premiums and out-of-pocket expenses, could be tax-deductible. There seemed to be some interest from the panel, as well as the other senators in the room, as to what this could look like in practice.

Week Ahead: Lawmakers Return to HC Leftovers

Like millions of Americans this week, lawmakers will be returning from a holiday break and will be working through a pile of leftovers. But for lawmakers, it won’t be turkey sandwiches and pumpkin pie; it will be negotiations over continuing the enhanced advance premium tax credits (APTCs). So, let’s get into it. Welcome to the Week Ahead!

The Administration

President Trump made waves before Thanksgiving by teasing a potential two-year extension of enhanced APTCs with changes in eligibility requirements. However, after reportedly receiving a cold reception from Capitol Hill conservatives and an outright rejection from House Democratic health care leaders, President Trump left town. As he did, the President told reporters that he’d prefer not to extend the tax credits at all, but some kind of extension may be needed. This has left congressional Republicans without a clear understanding of the President’s position at a time when they are divided on how to move forward on this issue.

Meanwhile, the tragic shooting of two National Guard members in the heart of DC, has caused President Trump to pivot towards non-health care issues. President Trump is now calling for additional National Guard troops to be deployed to the District and for green card applications to be reviewed since the alleged shooter was an Afghan refugee.

The Senate

As turkey is finished and holiday music fills the air, senators on both sides of the aisle are discussing the enhanced APTC issue with care. Senate Majority Leader John Thune (R-SD) promised Senate Democrats a vote on legislation of their choice to extend the tax credits in exchange for reopening the government. However, Republican health care leaders in the Senate, such as HELP Committee Chair Bill Cassidy (R-LA), have been pushing for a GOP health care reform bill that would redirect enhanced APTC funding to tax-free accounts. This idea is popular with President Trump and congressional conservatives.

We expect Sen. Cassidy to continue pressing to redirect the APTC funding to tax-free accounts when he presides over a HELP Committee hearing on December 3 on rising health care costs. Senate Finance Committee Democrats opposed this idea during a November 19 hearing on health care costs, and Ranking Member Ron Wyden (D-OR) even published a report criticizing the proposal.

The hearing will feature an ideological battle with the president of the Council for Affordable Health CoverageCouncil for Affordable Health Coverage, which advocates for lowering health care costs through marketplace principles, pitted against the national coordinator of the progressive Physicians for a National Health Program.

On a “clean extension” of current policy on APTCs, Sen. Jeanne Shaheen (D-NH) has said she has “had constructive conversations” with Republican senators about extending the enhanced APTCs. Certain GOP senators, such as Sens. Susan Collins (R-ME), Thom Tillis (R-NC), and Lisa Murkowski (R-AK), have expressed support for extending the enhanced APTCs, although for differing lengths of time and with differences in what changes (such as restricted income eligibility requirements) they would need to see. Notably, both Sens. Collins and Murkowski are on the Senate HELP Committee.

We are also keenly watching for the Senate Appropriations Committee to make moves this week on a minibus of appropriations legislation, which could include the Labor-HHS funding bill.

The House

Any discussion of how to finish the leftovers on the congressional health care policy plate will need to include more than just the Senate. House Speaker Mike Johnson (R-LA) has yet to commit to voting on legislation to extend the enhanced APTCs and has said that House Republicans have little interest in doing so. But that doesn’t mean things aren’t happening in the lower chamber.

House Democratic leadership has filed a discharge petition to force Speaker Johnson to vote on legislation to extend the enhanced APTCs for three years. To force a vote on the legislation, six Republicans would need to join the current 212 Democrats on the discharge petition to reach the required 218 signatories. This would be a tough lift, but a handful of moderate House Republicans and those at risk of losing their seats in 2026 have voiced support for a one-year extension of the enhanced APTCs.

If House Democrats would file a discharge petition on a shorter-term extension, they may find the votes needed to force a vote on such a bill. Key Republicans to watch include Reps. Jen Kiggans of Virginia, Young Kim and David Valadao of California, Jeff Hurd of Colorado, Tom Kean of New Jersey, Juan Ciscomani of Arizona, and Mike Lawler of New York.

The House is also set to consider a couple of other health care bills this week under suspension of the rules. The first of these bills, H.R.4313, the Hospital Inpatient Services Modernization Act, would reauthorize the hospital-at-home waiver for five years. The second bill, H.R.1262, the Give Kids a Chance Act, would expand the Food and Drug Administration’s authority with respect to research on rare pediatric diseases and renew the Pediatric Rare Disease Priority Review Voucher Program through September 30, 2029.

Outside Washington, voters in Tennessee’s 7th congressional district will head to the polls on December 2 for a special election to replace the recently retired Rep. Mark Green. Despite being a district that President Trump carried by more than 20 points, the polling has been surprisingly close. It will be important to keep an eye on this and other upcoming special elections as Speaker Johnson continues to deal with a very thin majority ahead of what could be a very difficult midterm election.

House Health Care Hearings this Week 

  • December 2: House Ways and Means Oversight Committee hearing on Organ Procurement Organizations
  • December 3: House VA Committee Legislative hearing, including the Guard Veterans’ Health Care Act

And don’t forget, the Medicare Payment Advisory Commission is meeting December 4-5 with a packed agenda.  We missed ya – glad you’re back!

There You Have It

We’ve officially entered the holiday season, and our team at Chamber Hill Strategies will be kicking it off by visiting Winter Wonderfest at Nationals Park! How are you celebrating the holiday season? Let us know. Make it a great week!

Subscribe to Us Now!

Be a DC insider by getting our updates straight to your inbox