Check out our expert take on key activity shaping health care policy
Insights
Featured Blogs
With Congress back, the long recess is giving way to high-stakes maneuvering. Congress returns with less than a month to hash out a continuing resolution (CR) before government funding lapses, and deadlines across health policy are stacking up. So, let’s get into it – welcome to the Week Ahead!
The Administration
The CDC is grappling with a sudden leadership vacuum after Director Susan Monarez was fired just weeks after her confirmation. Multiple senior officials resigned in protest, and protest actions erupted among CDC staff. For now, Deputy HHS Secretary Jim O’Neill has assumed the role of acting CDC director. Will the administration seek a new head that aligns with the vaccine policies of Secretary of Health and Human Services (HHS) Robert F. Kennedy Jr., or hold for now? Don’t forget – the CDC director used to simply be appointed and not Senate confirmed.
September isn’t just back to school season; it’s also crunch time for the Rural Health Transformation Fund. States are eagerly waiting for the administration to start publish guidelines and next steps for applications. The clock is ticking toward the December 31, 2025 deadline, so once guidance is out, the scramble to put together strong proposals will begin.
Several states aren’t waiting around—no less than 20 states have already signaled their interest with early requests for information (Alaska, Georgia, Hawaii, Illinois, Indiana, Mississippi, Missouri, Montana, Nevada, North Carolina, North Dakota, Pennsylvania, Oklahoma, Oregon, South Carolina, South Dakota, Texas, Utah, Washington and Wisconsin). Their enthusiasm shows just how much demand there is for federal support to strengthen rural health care, whether through workforce investments, telehealth, or new models of care.
The Senate
Secretary RFK Jr. will be at the head of the classroom when he heads to the Senate Finance Committee on September 4 to walk through the President’s health agenda. Expect Senate Republicans to grade his progress on the Make America Healthy Again (MAHA) initiative, while Democrats are likely to raise their hands with tough questions on the new COVID-19 vaccine guidelines.
But Sec. Kennedy isn’t the only one getting homework this fall. Senate Majority Leader Chuck Schumer (D-NY) has been pushing Republicans to extend advanced premium tax credits (APTCs) that are set to expire at year’s end. Health plans, meanwhile, are sweating it trying to figure out how these changes might expand coverage and how to structure their plans for PY2026.
Where are Senate Republicans on this? At least five or six have openly discussed the importance of extending APTCs—but one question is whether Republicans will insist on paying for the tax credits with offsets or look to the study guide of the One Big, Beautiful bill which didn’t offset many of the Trump-era tax cuts. Either way, the debate this month could shape the contours of coverage and costs for years to come.
The House
The House is back in session with just 14 legislative days left before the continuing resolution (CR) expires. Think of it as the final exam no one can afford to fail. Their task is to keep the government funded with a swath of health extendersset to expire on September 30 as well.
With special elections happening in Virginia and Arizona – and what is expected to be a two-seat pick up for Democrats – and Rep. Kat Cammack (R-FL-3) going on maternity leave, House Republicans are facing what could soon be a one-seat margin. The real question: Can House Republican leaders keep their conference together long enough to turn in a passing grade by September 30? Remember the CR needs bipartisan Senate support to pass, and Senate Democrats are already upset at the President’s pocket recissions package announced on August 29.
House Health Hearings
- September 3: House Energy and Commerce Health Subcommittee hearing on advancing health care through AI
There You Have It
Back-to-school season is here! And that means MedPAC and MACPAC start their new sessions as well. Chamber Hill Strategies sends everyone best wishes for a healthy and successful year ahead.
As Congress enters the final stretch of fiscal year 2025, a wide range of health care programs are set to expire on September 30, 2025, unless Congress takes action. These “health care extenders” cover everything from primary care and rural hospitals to Medicare telehealth services and workforce programs. Many of them have been renewed on a short-term basis for years—often tucked into year-end spending bills. But as the deadline looms, uncertainty grows for providers, patients, and public health programs.
Here’s a breakdown of what’s expiring.
Primary Care and Workforce Programs
Several major programs aimed at improving access to care in underserved areas are set to expire:
Community Health Centers (CHCs): CHCs provide essential primary care to nearly 30 million patients annually. Their core funding—known as the 330 Grant—is set to lapse without an extension of the Community Health Center Fund.
National Health Service Corps (NHSC): The NHSC supports primary care clinicians who work in shortage areas through scholarships and loan repayment. It relies heavily on the same fund that supports CHCs.
Teaching Health Centers Graduate Medical Education: Teaching Health Centers train medical residents in community-based settings. Without renewed funding, many could lose the ability to continue their residency programs.
Public Health Programs
Critical public health initiatives are also facing the end of federal funding:
Special Diabetes Programs: The Type 1 Diabetes program funds NIH research and the program for Indians supports tribal and Indian Health Service services.
Personal Responsibility Education Program: This program funds evidence-based initiatives to reduce teen pregnancy and promote adolescent health.
Medicare Extenders
Several Medicare provisions with significant implications for rural providers and seniors will expire:
Medicare-Dependent Hospital (MDH) Program: Provides additional funding to rural hospitals where a high percentage of patients are on Medicare
Low-Volume Hospital Payment Adjustment: Supports rural hospitals with limited inpatient volume to help them remain financially viable
Work Geographic Practice Cost Index (GPCI) Floor: Ensures that Medicare payments to rural physicians aren’t reduced unfairly based on geographic payment formulas
Telehealth Flexibilities: These pandemic-era provisions include waivers for geographic restrictions, audio-only telehealth, and expanded provider eligibility
Hospital at Home Waiver: CMS authority to allow acute-level care to be delivered at home under Medicare
Ground Ambulance Add-On Payments: Payment increases for rural and super-rural ambulance services
Medicare Quality Measurement Support: CMS funding for developing and endorsing Medicare quality metrics
Medicare Outreach and Enrollment Support: Assistance programs that help low-income seniors navigate Medicare
Medicaid and Behavioral Health
Medicaid Disproportionate Share Hospital (DSH) Payment Cuts: Delayed cuts to safety-net hospitals are scheduled to take effect. Without another delay, hospitals serving large numbers of low-income or uninsured patients would lose significant funding.
Certified Community Behavioral Health Clinics (CCBHCs): The original demonstration authority for CCBHCs in 2016 states will expire. While the program is now an optional Medicaid benefit, not all states have opted in.
Other Key Programs
Conrad 30 Waiver Program: Allows international medical graduates on J-1 visas to stay in the U.S. in exchange for practicing in underserved areas
Children’s Hospital Graduate Medical Education (CHGME): Supports pediatric residency programs
What Happens Next?
With dozens of health care programs scheduled to expire on September 30, 2025, Congress faces a significant number of time-sensitive decisions. Here are their options:
- Make some or all of these programs permanent
- Extend some or all of these programs for a year or more
- Align the extension of some or all of these programs with a continuing resolution to fund the entire federal government past September 30, 2025
If past is prologue, Congress will delay making permanent decisions on these programs and opt for some sort of extension. While health care providers need certainty to continue or revise programs, unfortunately Congress – regardless of which party is in control – has disappointed the health care sector before. But if faced with no extension or elimination of funding and authority, health care providers will be forced to support short-term patches.
Is anyone even working in D.C. in August?
If you’ve ever tried to schedule a meeting in Washington during August, you’d be forgiven for thinking the entire federal government evaporates into thin air. Lawmakers vanish. Hearing rooms go dark. Suits are replaced by polos. Surely nothing important is happening, right?
Wrong.
While Congress heads home for its traditional District Work Period—hosting town halls and visiting local businesses—federal agencies are deep in the weeds drafting, publishing, and collecting comments on major regulatory proposals. In fact, some of the most consequential Medicare rules of the year drop precisely when Capitol Hill is empty.
Congressional District Work Period: A Historical Snapshot
The August break dates back to the mid-20th century, when longer sessions, heavier legislative workloads, and a sweltering, pre-air-conditioned Washington led lawmakers to seek respite during the hottest part of the year. But it wasn’t until the 1970s—amid government reforms and rising constituent demands—that Congress institutionalized this district-focused period in the 1970 Legislative Reorganization Act.
What Congress Is Doing
During August, Members of Congress actively:
- Hold town halls and community events
- Visit schools, businesses, and local organizations
- Engage with civic and media stakeholders
- Address constituent concerns and casework
This time back home isn’t a vacation—it’s a political imperative. (Especially in an election year.)
What Agencies Are Doing
Back in Washington, regulatory agencies like CMS, HHS, and FDA are hard at work. The August calendar often includes:
- Release of Medicare payment rules for the next calendar year
- Opening of public comment periods for providers, associations, and advocates
- Data and policy development for final rules due in the fall
- Stakeholder meetings, technical briefings, and internal regulatory review
Currently Open Medicare Rules
Here’s what’s live now on Regulations.gov and requires action in the very near-term:
- CY 2026 ESRD Prospective Payment System (CMS20250240) – Comments due August 29
- Provider Enrollment Changes (CMS20250242) – Comments due August 29
- CY 2026 Home Health Prospective Payment System – (CMS202512347) – Comments due September 5
- CY 2026 Medicare Physician Fee Schedule & QPP (CMS1832P) – Comments due September 12
- CY 2026 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Proposed Rule – (CMS202513360) – Comments due September 15
These comment windows are crucial—and they don’t wait for Congress to return.
Why August Matters
For health care advocates, it’s one of the busiest months of the year. Here’s what we are doing:
- Meeting with lawmakers in-district to shape fall legislative priorities
- Hosting site visits
- Catching up Congressional staff who have a bit more time to talk
- Analyzing proposed rules and draft formal comments
August does mean a break but it doesn’t mean sitting back.
On July 31, 2025, the Centers for Medicare and Medicaid Services (CMS) released the Fiscal Year 2026 Skilled Nursing Facility Prospective Payment System (SNF PPS) Final Rule. A fact sheet from CMS can be found here. The final rule takes effect on October 1, 2025.
UPDATES TO SNF PAYMENT RATES
As part of the rule, CMS will update SNF rates by 3.2%. This update is based on a final SNF market basket of 3.3%, increased by a 0.6% market basket forecast error adjustment, and reduced by a 0.7% productivity adjustment. The rule is projected to increase SNF payments by $1.16 billion compared to payments in FY25.
A forecasting error occurs when the projected SNF market basket increase differs from the actual increase, with CMS applying an adjustment if the difference exceeds 0.5%. For FY24, the SNF market basket was projected at 3.0% but increased by 3.6%, triggering a 0.6% forecast error adjustment. CMS attributes this error to underestimating the impact of higher-than-expected labor cost growth, particularly in wages and benefits for SNF staff, which drove the actual market basket increase above projections.
The FY26 final rule’s net market basket update of 3.2% is 0.4% higher than the 2.8% update in the proposed rule. Specifically, the market basket update rose from 3.0% to 3.3% (due to updated forecasts using more recent cost/claims data through the first quarter of 2025 and reflecting ongoing price pressures), while the productivity adjustment decreased from 0.8% to 0.7% based on revised projections of lower economic growth.
SNF QUALITY REPORTING PROGRAM (QRP)
CMS finalized amendments to the SNF QRP reconsideration policy for FY26, allowing SNFs to request extensions for filing reconsideration requests due to extraordinary circumstances. Requests must be submitted via email within 30 days of noncompliance notification, including the SNF’s CCN, business details, contact information, reason for delay, and supporting evidence like photos or media reports. For this change, CMS estimates an incremental administrative burden of 51 hours annually across 202 requests at $2,391.90.
For FY27, CMS finalized the removal of four SDOH standardized patient assessment data elements from the Minimum Data Set (MDS), effective for residents admitted on or after October 1, 2025. The removed items consist of one living situation element (R0310), two food elements (R0320A and R0320B), and one utilities element (R0330). This change reduces the SNF annual reporting burden by 31,791.20 hours and $2,228,563.12 in costs across 15,253 SNFs, based on a $70.10 hourly composite wage rate for RNs and LPNs.
CMS received varied feedback on future QRP enhancements through three RFIs, including measure concepts for delirium, interoperability, nutrition, and well-being. On a potential delirium measure, supporters noted its value for care, but opponents raised concerns over underreporting, feasibility, and added burden for rural SNFs. For shortening data submission deadlines to 45 days post-quarter, some commenters worried about error rates and advocated for 60 days or phased implementation with technical support. Regarding digital quality measurement via FHIR, stakeholders urged a minimum 12-month transition, voluntary pilots, grants for IT adoption, and safeguards for facilities with limited connectivity. Input generally stressed stakeholder engagement to minimize disparities and administrative load.
SNF VALUE-BASED PURCHASING (VBP) PROGRAM
CMS finalized the scoring methodology for the SNF Within-Stay Potentially Preventable Readmission (WS PPR) measure beginning FY28, replacing the Skilled Nursing Facility 30-Day All-Cause Readmission Measure (SNFRM) and using a hierarchical logistic regression model for risk adjustment. The measure assesses readmissions during SNF stays with a 2-year data period to enhance reportability for lowvolume SNFs. Codified at §§ 413.338(e)(1) and (e)(3), it aims to improve performance evaluation accuracy. Commenters supported adoption but raised concerns for low-volume rural SNFs, citing their historically better performance. Suggestions to avoid score inversion for clarity and add bonuses for Tribal facilities were not adopted. This adjustment encourages SNFs to focus on preventing readmissions mid-stay, which could lower overall healthcare expenditures and enhance care continuity.
CMS finalized performance standards for FY28 measures, including SNF HAI (achievement threshold 0.92183, benchmark 0.94491), Total Nurse Staffing Hours (3.29119, 5.87448), Total Nursing Staff Turnover, Falls with Major Injury (Long-Stay), Hospitalizations per 1,000 Long-Stay Resident Days, and DC Function, with minor differences from proposed values. For FY29, standards cover DTC PAC SNF (0.43478, 0.68049) and SNF WS PPR (0.86219, 0.92400). Standards follow the FY17 methodology, with other FY29 measure estimates slated for the FY27 proposed rule. No baseline or performance periods were specified. No specific feedback was provided on these standards. Establishing these thresholds helps facilities prioritize specific metrics to boost their VBP scores and secure better payment adjustments.
CMS finalized the elimination of the Health Equity Adjustment (HEA) bonus points from SNF VBP scoring. Adopted in FY24, the HEA awarded extra points to SNFs serving at least 20% dual-eligible residents while excelling in quality measures like preventing readmissions or reducing falls. It was created to address health disparities, encouraging SNFs to prioritize quality for low-income patients who often face worse outcomes. As part of the HEA, the VBP payback percentage (the portion of the 2% withhold returned as incentives based on performance scores) was adjusted. By raising this payback from 60% to ~66%, the HEA would have redistributed an additional $50–60 million annually in bonuses without cutting other SNF payments. This would have supported facilities in underserved areas without penalizing others in the program. CMS had previously projected ~15% of SNFs (~2,250 facilities) would have qualified for the enhanced HEA bonus payments.
ICD-10 MAPPING
The ICD-10 mapping in the SNF PPS refers to the system used under the Patient-Driven Payment Model (PDPM) to assign primary diagnoses from Medicare Part A claims to clinical categories for the physical therapy, occupational therapy, speech-language pathology, and non-therapy ancillary components, determining case-mix adjustments and payment rates, with mappings updated annually to reflect new codes and clinical accuracy.
In the FY26 final rule, CMS finalized technical revisions to these PDPM ICD-10 code mappings effective October 1, 2025, through September 30, 2026, specifically changing assignments for 34 new ICD10 codes effective October 1, 2024: 33 codes (covering conditions like Type 1 diabetes mellitus, hypoglycemia, obesity, anorexia nervosa, bulimia nervosa, binge eating disorder, pica, and rumination disorder) were reassigned to the “Return to Provider” category to prevent their use as primary diagnoses for SNF stays, while one code (G90.81 for serotonin syndrome) was shifted from “Acute Neurologic” to “Medical Management.”
According to CMS, these shifts ensure mappings align with current clinical guidelines and coding practices, reducing inappropriate categorizations that could affect reimbursement. No updates were made to Hierarchical Condition Category versions for the SNF Value-Based Purchasing Program or the Within-Stay Potentially Preventable Readmission measure.
REQUESTS FOR INFORMATION (RFIS)
As part of the final rule, CMS does not issue any new requests for information (RFIs). However, it references a standalone RFI on streamlining regulations and reducing administrative burdens, issued separately on January 31, 2025, in response to Executive Order (EO) 14192. To that end, the final rule encourages interested stakeholders to submit feedback on that matter by September 15, 2025.
We trust you found this summary useful. Please reach out to us with any questions.
©2025 Chamber Hill Strategies. All rights reserved. Any use of these materials including reproduction, modification, distribution or republication, without the prior written consent of Chamber Hill Strategies is strictly prohibited.
